Boris Volodarsky

Boris Volodarsky

Orrick, Herrington & Sutcliffe LLP

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FHFA Updates Requirements for Freddie and Fannie Sales of Non-Performing Loans

On March 2, FHFA announced changes to requirements for sales of non-performing loans (NPLs) by Freddie and Fannie to reduce the number of severely delinquent loans held in their inventories and to transfer risk to the private...more

3/9/2015 - Delinquent Borrowers Fannie Mae FHFA Freddie Mac Mortgages

Rating Agency Developments

On March 6, Fitch revised its criteria for rating granular corporate balance-sheet securitizations (SME CLOs). On March 5, Moody’s revised its global approach to data quality evaluation. On March 3, Kroll released CMBS...more

3/9/2015 - CMBS Fitch Moody's Rating Agencies RMBS S&P Securitization Vehicles

SEC Fee Rate Advisory #4

On February 27, the SEC announced that the Section 31 fee rate for fiscal year 2015 will remain at the current rate of $18.40 per million....more

3/9/2015 - Fees Filing Fees SEC

Fed Announces Dates of Stress Test Releases

On February 12, the Fed announced that results from the latest supervisory stress tests conducted as part of Dodd-Frank will be released on March 5, and the related results from the Comprehensive Capital Analysis and Review,...more

2/24/2015 - Banks Dodd-Frank Financial Institutions Stress Tests

Rating Agency Developments

On February 18, DBRS released its methodology for assessing RMBS servicing advance transactions. On February 16, Fitch released its criteria for assessing covered bonds of European public entities....more

2/20/2015 - Bonds DBRS Fitch Rating Agencies RMBS

SEC Proposes New Rules for Security-Based Swap Information Reporting

On February 11, the SEC issued proposed new rules and rule amendments to Regulation SBSR—Reporting and Dissemination of Security-Based Swap Information. New rules would require platforms to report to a registered...more

2/16/2015 - SEC Security-Based Swaps Swaps

SEC Proposes Rules for Disclosure of Hedging Policies

On February 9, the SEC issued proposed rules that are intended to enhance disclosure of company hedging policies for directors and employees, as mandated by Dodd-Frank. The proposal would require disclosure about whether...more

2/12/2015 - Disclosure Requirements Dodd-Frank Hedging Proposed Regulation Publicly-Traded Companies SEC

Federal Reserve Proposes to Expand the Applicability of Board’s Small Bank Holding Company Policy Statement

On January 29, Federal Reserve Board (Fed) invited public comment on a proposed rule to expand the applicability of the Board’s Small Bank Holding Company Policy Statement (Policy Statement) for small bank holding companies...more

2/10/2015 - Bank Holding Company Banking Sector Banks Community Banks Federal Reserve

CFPB Issues Proposal To Facilitate Access To Credit In Rural And Underserved Areas

On January 29, the Consumer Financial Protection Bureau (CFPB) proposed several changes to its mortgage rules to facilitate lending in rural and underserved areas. The proposed rule would increase the number of financial...more

2/10/2015 - Banking Sector CFPB Financial Institutions Mortgage Lenders Mortgages

Rating Agency Developments

On February 6, Moody’s restated its approach to rating trade receivables-backed transactions. On February 5, S&P restated its criteria for rating global non-diversified auto dealer floorplan ABS. On February 4, DBRS requested...more

2/10/2015 - Banking Sector Fitch Moody's Rating Agencies

Guidance on Private Student Loans With Graduated Repayment Terms Released

On January 29, federal financial regulatory agencies in partnership with the State Liaison Committee (SLC) of the Federal Financial Institutions Examination Council, issued guidance for financial institutions on private...more

2/10/2015 - CFPB Consumer Lenders FDIC Federal Reserve Lenders Private Student Loans Student Loans

SEC Extends Expiration Dates to Interim Final Rules Providing Exemptions for Certain Security-Based Swaps

On February 5, the SEC adopted amendments to the expiration dates in its interim final rules that provide exemptions under the securities laws for certain security-based swaps. Under the amendments...more

2/9/2015 - SEC Security-Based Swaps Time Extensions

Financial Stability Oversight Council Announces Changes to Nonbank Designations as Systemically Important

On February 4, the Financial Stability Oversight Council (Council) today announced changes to certain practices relating to its process for reviewing nonbank financial companies for potential designation. Nonbank financial...more

2/9/2015 - Federal Reserve FSOC Nonbank Firms Supervision

FHFA Proposes Minimum Financial Eligibility Requirements for Fannie and Freddie Seller/Servicers

On January 30, the Federal Housing Finance Agency (FHFA) today proposed new minimum financial eligibility requirements for Fannie Mae and Freddie Mac Seller/Servicers. The proposed minimum financial requirements include net...more

2/9/2015 - Eligibility Fannie Mae FHFA Freddie Mac

SEC Publishes Technical Corrections to Regulation AB II

On February 4, the SEC released certain technical corrections to rules that were published in the Federal Register on September 24, 2014. The changes effect Regulation AB and other rules governing the offering process,...more

2/9/2015 - Asset-Backed Securities Disclosure Requirements Offerings Regulation AB Reporting Requirements SEC

Rating Agency Developments

On January 22, Fitch released its rating criteria for rating RMBS in Latin America. On January 22, Moody’s released its global methodology for rating small and medium size enterprise balance sheet securitizations. On January...more

1/27/2015 - ABS DBRS Fitch Moody's RMBS

The Fed Forms Advisory Council

On January 16, the Fed announced the formation of a new advisory council that will be comprised of individuals with consumer- and community development-related expertise. The council will meet semiannually with the Fed’s...more

1/26/2015 - Advisory Board Federal Reserve

CFPB Finalizes Minor Changes to “Know Before You Owe” Rules

On January 20, CFPB finalized two minor modifications to the “Know Before You Owe” mortgage disclosure rules. The changes, which were proposed in October 2014, address when consumers will receive updated disclosures after...more

1/26/2015 - CFPB Construction Loans Disclosure Requirements Interest Rates Material Disclosures Mortgages

Fee Rate Advisory #3 for Fiscal Year 2015

On January 15, the SEC announced that starting on Feb. 14, 2015, the fee rates applicable to most securities transactions will be set at $18.40 per million dollars. Each SRO will continue to pay the Commission a rate of...more

1/26/2015 - SEC Securities Transaction Fees

SEC Adopts New Rules for Security-Based Swap Market

On January 14, the SEC adopted new rules that will require security-based swap data repositories (SDRs) to register with the SEC and prescribe reporting and public dissemination requirements for security-based swap...more

1/19/2015 - Dodd-Frank New Regulations SEC Swap Data Repositories Title VII

FHFA Issues 2015 Scorecard for Fannie, Freddie and Common Securitization Solutions

On January 14, FHFA released the 2015 Scorecard? outlining specific priorities for Fannie Mae, Freddie Mac and their joint venture, Common Securitization Solutions, LLC. The Scorecard assesses Fannie and Freddie’s performance...more

1/19/2015 - Fannie Mae FHFA Freddie Mac

Rating Agency Developments

On January 12, DBRS released its methodology for operational risk assessment for European structured finance servicers. On January 8, Moody’s revised its approach to rating single family rental securitizations....more

1/19/2015 - DBRS EU Moody's Mortgage-Backed Securities

Rating Agency Developments

On January 7, Fitch revised its criteria for rating U.S. Public Finance Short-Term Debt. On January 7, DBRS released its methodology for surveillance of North American CMBS. On January 6, Fitch released its global criteria...more

1/9/2015 - Asset-Backed Securities CMBS DBRS Fitch Public Financing Rating Agencies RMBS

SEC Issues Revisions to Regulation AB Telephone Interpretations

On December 9, the SEC issued Compliance and Disclosure Interpretations (“C&DIs”) that comprise the SEC’s interpretations of the rules adopted under Regulation AB II and the Securities Act and the Exchange Act. The new C&DIs...more

12/12/2014 - Compliance Regulation AB SEC Securities Exchange Act

Treasury and HUD Announce Changes to Making Home Affordable Program

On December 4, Treasury and HUD announced changes to Making Home Affordable (MHA) to better assist struggling homeowners. The changes are designed to motivate homeowners in MHA to continue making timely mortgage payments. The...more

12/12/2014 - Affordable Housing Home Affordable Refinance Program HUD Loan Modifications Mortgages U.S. Treasury

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