Dentons US LLP Developments & Regulatory Issues in Loan Level Data Reporting STUDENT LOAN LEGAL MEETING EDUCATION FINANCE COUNCIL NATIONAL COUNCIL OF HIGHER.

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Presentation transcript:

Dentons US LLP Developments & Regulatory Issues in Loan Level Data Reporting STUDENT LOAN LEGAL MEETING EDUCATION FINANCE COUNCIL NATIONAL COUNCIL OF HIGHER EDUCATION RESOURCES Moderator: Lauris G. L. Rall, Partner Dentons US LLP New York, New York August 5, 2013

Dentons US LLP 2 Locations

Dentons US LLP 3 Offices KeyCanadaUnited StatesEurope Central and Eastern Europe AfricaMiddle EastAsia Pacific Offices Associate offices Facilities Associate firms + Special alliance firms Calgary Edmonton Montréal Ottawa Toronto Vancouver Atlanta Boston Chicago Dallas Kansas City Los Angeles Miami New Orleans New York Phoenix San Francisco Short Hills Silicon Valley St. Louis Washington, DC Barcelona Berlin Brussels Frankfurt Madrid Paris Zurich Bratislava Bucharest Budapest Istanbul Prague Warsaw Accra Algiers Bissau Bujumbura Cairo Cape Town Casablanca Dar Es Salaam Johannesburg Kampala Kigali + Lagos Luanda Lusaka Maputo Nairobi Nouakchott Port Louis Praia São Tomé Tripoli Abu Dhabi Amman Beirut Doha Dubai Kuwait City Manama Muscat Riyadh Beijing Hong Kong Shanghai Singapore United KingdomRussia and CISCentral Asia London Milton Keynes Kyiv Moscow St. Petersburg Almaty Ashgabat Baku Tashkent

Dentons US LLP 4 THE STUDENT LOAN DATA LANDSCAPE INCREASING GOVERNMENT FOCUS ON LOAN LEVEL DATA JULY 2012 CFPB REPORT TO CONGRESS ON PRIVATE STUDENT LOANS WAS BASED ON COLLECTED DATA OF 5,456,689 UNIQUE RECORDS AND 3,478,146 DISTINCT BORROWER - LENDER PAIRS - 9 MAJOR LENDERS PROVIDED LOAN LEVEL DATA THE CFPB REPORT INCLUDED SUBSTANTIAL ANALYSES BASED ON THE LOAN LEVEL DATA COLLECTED AND PRESENTED RECOMMENDATIONS TO CONGRESS IN PART ON THAT DATA

Dentons US LLP 5 PROPOSED FEDERAL REGULATION OF LOAN LEVEL DATA IN STUDENT LOAN SEC REG AB II RULE ISSUER REPORT ON ASSETS USED IN ABS - POSSIBLE USE OF THIRD PARTY DILIGENCE COMPANY - REQUIRED DISCLOSURES IN OFFERING DOCUMENTS NEW RULES WILL SIGNIFICANTLY INCREASE THE INFORMATION FOR THE STUDENT LOANS INCLUDED IN AN ASSET POOL THAT COLLATERALIZES STUDENT LOAN ABS, BOTH AT THE TIME OF THE OFFERING AND ON AN ONGOING BASIS ISSUERS WILL BE REQUIRED TO PROVIDE STANDARDIZED ASSET LEVEL DATA AS REQUIRED UNDER A NEW SCHEDULE L TO REG AB - 28 ITEMS RANGING FROM PAYMENT STATUS TO SCHOOL TYPE TO BORROWER FICOS AND INCOME VERIFICATION

Dentons US LLP 6 ASSEMBLY AND FILING OF STUDENT LOAN ABS LOAN LEVEL DATA ISSUERS WILL NEED TO PREPARE DATA FOR FILING IN EXTENSIBLE MARKUP LANGUAGE AND MAKE AN SEC EDGAR FILING INVESTORS WILL BE ABLE TO DOWNLOAD DATA FROM EDGAR FILINGS INTO SPREADSHEETS FOR ANALYSIS ENHANCED POOL DATA WILL ALSO BE REQUIRED - INCLUDING LOANS ORIGINATED UNDER EXCEPTIONS TO UNDERWRITING CRITERIA AND LOANS THAT HAVE BEEN SUBJECT TO MODIFICATIONS

Dentons US LLP 7 TIMELINE FOR ADOPTION OF LOAN LEVEL DATA REQUIREMENTS ORIGINAL AB II PROPOSED REGS ISSUED IN 2010 SEC RE-PROPOSED AB II WITH DODD-FRANK MODIFICATIONS AND REQUEST FOR ADDITIONAL COMMENTARY IN FOCUS ON CONSUMER BORROWER PRIVACY SUBSTANTIAL INDUSTRY COMMENTARY IN POSITIONS ADVOCATING USE OF GROUPED ACCOUNT DATA OR REP LINES LIKELIHOOD OF PROMULGATION OF REG AB II IN 2013 OR 2014

Thank you Dentons US LLP 1221 Avenue of the Americas New York, NY USA © 2013 Dentons Dentons is an international legal practice providing client services worldwide through its member firms and affiliates. This publication is not designed to provide legal or other advice and you should not take, or refrain from taking, action based on its content. Please see dentons.com for Legal Notices.