Forums in Focus: Joint Transparency Initiative Targeting the SASB Market

July 21, 2026

To address the ongoing structural evolution of the CRE finance landscape, the Investment-Grade (IG) Bondholders Forum and the Issuer Forum recently convened a joint session aimed at enhancing reporting practices and transparency across the SASB market.

Acknowledging that the market requires data transmission frameworks that match its modern complexity, the two forums reviewed several primary operational areas to drive consistency, mitigate data friction, and explore the feasibility of establishing collaborative industry best practices.

Key Areas for Reporting Enhancement

  • Data Room Standardization: To build efficiency during the pre-marketing and structural phases of a transaction, the Forums agreed to work towards developing a standardized checklist of feasible documents for SASB data rooms. While complete information is often subject to ongoing negotiations before a deal is finalized, establishing a consistent template—including baseline appraisal metrics, underwriting assumptions, and third-party reports—is intended to streamline due diligence.
  • Capital Stack Reporting Clarity: For pari passu structures and loans with complex capital stacks, tracking distinct debt layers remains an operational priority. The forums noted that establishing a standardized format for reporting capital stack details is an objective they intend to work towards. The Issuer Forum noted that existing master tape data lines could potentially be converted into a consistent file type, while CREFC indicated that this standardized capital structure layout could be integrated as a dedicated tab within the existing reporting Annex to help investors accurately capture transaction metrics.
  • Multi-Property Tracking and Releases: In multi-property SASB transactions, ensuring that investors receive timely visibility into asset releases and subsequent property-level financial metrics is critical. The IG Forum has agreed to work towards providing clear examples of transactions where property release tracking functions consistently, alongside examples where challenges persist. These case studies are intended to serve as a helpful baseline for productive engagement with the broader servicing community.
  • Optimizing Financial Data Flows: Addressing delays in property-level financial reporting was identified as an area for joint focus, reflecting the broader industry push for timely, transparent, and consistent reporting. The forums discussed exploring the feasibility of potential measures, such as implementing system flags to denote when financials are received, which could help market participants isolate whether reporting delays stem from borrower-level data delivery or subsequent processing timelines. 
  • Post-Modification Visibility: To maintain secondary market clarity, the forums highlighted that working towards standardizing the practice of posting completed loan modification documentation to trustee sites, once agreements are legally finalized, may support investor visibility. The forums warmth to this concept reflects a shared understanding that consistent access to updated loan parameters benefits the entire ecosystem.
  • Consistent Fee Disclosure: The conversation also covered fee disclosure frameworks within SASB transactions. The forums discussed evaluating a potential, threshold-based approach to help ensure transparency is balanced, predictable, and consistent across the wider industry.

Next Steps and Collaborative Implementation

Moving forward, the initiative aims to transition into a broader, collaborative phase focused on assessing how potential enhancements might align with the technical and operational capabilities of key market counterparties:

  • CREFC will work towards drafting a preliminary capital structure layout template for the Annex to gather initial, informal stakeholder feedback.
  • The Issuer and IG Forums have agreed to work towards outlining a recommended baseline data room document checklist.
  • CREFC plans coordinate a constructive dialogue with the servicing and special servicing communities to collaboratively review operational mechanics, with the goal of discussing how property release reporting, financial data tracking, and modification postings might be approached without creating undue cost friction or administrative burdens.

Please contact Rohit Narayanan (RNarayanan@crefc.org) with any questions.

Contact  

Rohit Narayanan
Managing Director,
Industry Initiatives
646.884.7569
rnarayanan@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2026 CRE Finance Council. All rights reserved.

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