JOSEPH CIOFFI

The OCC’s Crypto Charter Craze

The epic battle of state regulators versus federal agencies for the right to regulate online financial services shows no sign of ending soon. In 2019, a federal New York district judge found that the Office of the Comptroller of the Currency (OCC) lacks the authority to grant non-depository fintechs special purpose charters. Such charters would enable fintechs providing online financial services...

Read More

Of Forgiveness and Forbearance in Student Loan ABS

Last week, I moderated a panel on valuation and trends in student loan securitizations and the secondary market at the iiBig Virtual Education Finance & Loan Symposium. Below are some insights from me and my fellow panelists: Ian Rasmussen, Senior Director, ABS, at Fitch Ratings; Mark Weadick, Managing Director at SL Capital Strategies LLC; and Melvin Zhou, Director, ABS Consumer at Kroll Bond...

Read More

Under the Hood of Subprime Auto: The Timing’s Right for Introspection

It’s a change of seasons like no other before it. The weather is turning, vaccines are rolling, stimulus is arriving and maybe best of all, Hollywood is luring audiences back to movie theaters to watch titans collide above cities on the biggest screen possible. Down here on the ground, a new administration and an evolving regulatory landscape could bring titanic change to subprime auto. It’s...

Read More

The Future of Student Loan Reforms under the Biden/Harris Administration

With a full plate of health, safety and security priorities on the table and the challenge served up by a deeply divided Congress, the prospects are dim for substantial student loan forgiveness in the early stage of the Biden/Harris Administration. Still, we anticipate the White House will try to find meaningful ways to reform a space that has become a progressive lightning rod. Any significant...

Read More

A Housing Policy Wish List under a Biden/Harris Administration

2020 (and, by the looks of it, 2021) has taught us that predicting the future is no longer merely a fool’s errand as not even Nostradamus would find success in the prognostication business these days. Yet, as we said in our similar post on the subprime auto industry, we can’t let the uncertainty of the times prevent us from preparing for what may lie ahead in policy and programs from the...

Read More

After Electoral Dysfunction, What Subprime Auto Can Expect From a Biden Administration

It’s only fitting that we’ll end the year with more uncertainty, this time as a result of the elections. It seems safe to expect a Biden/Harris administration in January, but the road ahead remains a bit foggy pending the Georgia Senate run-off elections in January, the outcome of which will determine which party controls the Senate. Under Democratic control, we could see more progressive...

Read More

What Will the Change of Seasons Bring to Subprime Auto?

Our last market study, based on surveys conducted in the spring – before and then after the COVID-19 crisis began – found industry professionals surprisingly sanguine. Now, as the temperatures begin to cool and the virus rolls in waves across the country against the backdrop of a presidential election and continued uncertainty of future relief programs, we’ve gone back to market participants,...

Read More