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Recent changes to the regulatory treatment of mortgage servicing rights ("MSR"s) for financial institutions subject to Basel III, together with political and prosecutorial pressures, have resulted in a substantial increase in incentives for financial institutions to transfer their residential MSRs
On November 4, 2011, the Financial Stability Board (the "FSB"), an international board with a mandate from the G-20 Leaders to "develop a policy framework to address the systemic and moral hazard risks associated with systemically important financial institutions" ("SIFIs"), identified the first 29 SIFI banking groups ("G-SIBs") to be listed as global SIFIs ("G-SIFIs") based upon their size, complexity and systemic interconnectedness
