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CRE Finance World Summer 2015
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s of April 2015, the Servicers Forum had 656 members
and the IRP Committee had 163 members.
Servicers Forum Leadership:
Chair: Dan Olsen, KeyBank Real Estate Capital
Chair-Elect: Lindsey Wright, C-III Asset Management
Past-Chair: Tom Nealon, LNR Partners
IRP Committee Leadership:
Leslie Hayton, Wells Fargo
Heather Wagner, PNC/Midland
The Servicers Forum is not only the largest of CREFC’s Forums,
but it is also one of the most active. Currently the Servicers Forum
is engaged in numerous initiatives outlined in this article. Members
include Master Servicers, Special Servicers, Rating Agencies,
Trustees, Certificate Administrators, Operating Advisors, Data
Providers, and counsel, among others, making the Servicers Forum
the most comprehensive forum with representation from a wide
segment of industry participants. With nearly 700 individual members,
the Servicers Forum, together with the IRP Committee, plays an
integral role in setting industry standards and best practices for
the CMBS market. In addition to these important industry initiatives,
the Servicers Forum also promotes educational programming. This
year, we plan to host After-Work Seminars in Charlotte, Kansas
City, Miami, and San Francisco.
The industry is currently facing several regulatory challenges that
will be impacting the CMBS market, including Regulation AB II and
Risk Retention, which have a direct impact on the servicing sector.
CREFC is addressing implementation issues resulting from these
comprehensive rules through various working groups. In addition
to its efforts on regulatory issues, the Servicers Forum and IRP
Committee also address current market business challenges and
trends. There are many active working groups, some of which have
already released final best practice drafts and recommendations.
The Servicers Forum’s continued objective is the efficiency
and effectiveness of the execution of CMBS servicer related
responsibilities, especially with regard to communication and
timing, and the promotion of market transparency for all parties,
including investors.
Many of the initiatives the Servicers Forum is working on will
require coordination and support from the other CREFC forums
to ensure optimal results. We encourage other forum leaders to
reach out to the Servicers Forum Leadership with any ideas that
will improve our industry.
Here are the highlights of these various initiatives, including why
they are important to the market and when they go into effect.
Reg AB II Schedule AL Working Group — (Active)
Co-Chair Leslie Hayon, Wells Fargo
Co-Chair Kathleen Olin, CWCapital
In order to ensure a standardized industry approach to implementation
of the new asset-level disclosure and reporting requirements
in Reg AB II, which was finalized August 27, 2014, CREFC has
created a Schedule AL Working Group.
Schedule AL will be used for both the offering disclosure as well
as ongoing disclosures. While many of CREFC’s recommendations
regarding asset-level data points were adopted, the new Schedule
AL does not map exactly to the CREFC IRP or Annex A.
This working group is comprised of master and special servicers
and other market participants, and has conducted a line by line
comparison of the SEC’s required asset-level data points to the
CREFC IRP and Annex A to determine which fields are new or
similar, and how to report such information going forward in the
most efficient and useful manner.
Current Status
The working group held a fly-in meeting in Dallas on January 27
& 28 to conduct a line-by-line comparison of the SEC Schedule
AL and CREFC IRP. The data mapping draft document is currently
being reviewed by working group members. The working group
also held conference calls with XML experts from various master
servicers and trustees to review programming and cost estimates
for implementing the Schedule AL XML reporting requirements.
Next, the working group will reconvene to discuss finalizing the
data mapping document and to review procedures for producing
Schedule AL in XML format. It is expected that the trustee will be
the party responsible for filing Schedule AL with the SEC once it
is in XML.
17g-5 Best Practices — (Active)
Co-Chair Stacy Ackermann, K&L Gates
Co-Chair Adam Fox, Fitch Ratings
Co-Chair Iris Woo, Wells Fargo
Effective June 2010, The Securities and Exchange Commission
(SEC) promulgated a regulation, 17g-5, which imposed additional
disclosure and conflict of interest requirements on nationally
A
2015 Servicers Forum Overview
Dan Olsen
Senior Vice President
KeyBank Real Estate Capital
FORUM SPOTLIGHT