SFA Member Alert: SFA Publishes Reduced Compliance Scope for Closed-End Subordinate Lien Financing

Published on May 27, 2026

SFA Publishes Reduced Compliance Scope for Closed-End Subordinate Lien Financing

 

On May 26, 2026, the Structured Finance Association (SFA) published its Closed-End Second (CES) Reduced Compliance Scope, referred to as the SFA TRID Subordinate Lien Scope 1.0. Developed by SFA’s RMBS Third-Party Review Task Force, this framework establishes a standardized approach to compliance reviews for closed-end subordinate lien transactions. It is intended to provide members and third-party review firms with a clear, consistent baseline for loan-level due diligence while improving efficiency and reducing unnecessary complexity. The full TRID compliance scope remains available for use when a more comprehensive review is requested.

SFA will continue to engage with members and third-party review firms to support adoption and gather feedback as the industry begins implementing this framework. In the coming weeks, the Third-Party Review Task Force will also begin work on updates to SFA's TRID Grid 4.0.