SIFMA submitted comments regarding Federal Housing Finance Agency ("FHFA") guarantee fees ("g-fees") for Fannie Mae and Freddie Mac. SIFMA stated that efforts to reshape mortgage finance markets should carefully consider the costs, benefits, and likelihoods of success. Specifically, SIFMA explained that the question of appropriate g-fee levels should not be looked at in isolation, especially if g-fees are intended to be used as a policy lever to cause shifts in market dynamics outside of the government sponsored enterprises. Changes in g-fees, according to SIFMA, may cause originators to

SIFMA submitted comments to the U.S. Department of Treasury ("Treasury") regarding the development of a functioning private-label securities ("PLS") market for securitizations. SIFMA stated it is a "strong supporter" of the restoration of private-sector securitizations, noting that the recovery of this market is necessary for a "reinvigoration" of the housing system in the U.S. SIFMA also commented that it is time to review the housing finance system, and addressed a number of issues that need careful analysis, which included: how the regulatory framework governing mortgage lending has changed

SIFMA and the Mortgage Bankers Association ("MBA") submitted a joint comment letter to the Government National Mortgage Association ("GNMA") in response to its June 9, 2014 letter requesting feedback regarding the proposed combination of the Ginnie Mae I and II programs. In the letter, SIFMA identified specific issues that it is considering regarding combining the two Ginnie Mae programs and improving market execution, which include, among other things: considerations related to the wind-down of the Ginnie Mae I program and whether or not a conversion process is needed to allow Ginnie Mae I

The SEC announced that Thomas M. Piccone will head the National Exam Program in the Denver Office. In his new role, Mr. Piccone will oversee examinations of broker-dealers and transfer agents as well as investment advisers and investment companies throughout an eight-state region. See: Press Release.

Seton Hall University School of Law professor, Stephen J. Lubben, published a paper titled "Nationalize Clearinghouses!" which argues for the nationalization of clearinghouses ("CCPs") upon any failure. In his paper, Professor Lubben argues: (i) bailouts of clearing houses are inevitable, because Dodd-Frank makes their failure too disruptive to be politically tolerated; (ii) the U.S. needs to enact clear, ex ante procedures to deal with the failure of a clearinghouse and address the consequences of a bailout; and (iii) those consequences must include clearly delineated outcomes for the