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The TALF CLO Trilogy Concludes: Too Little, Too Late

The Fed throws a bone to the CLO market by reducing the non-call period from three years to one year, but this small victory will likely have little impact given the numerous obstacles which remain unaddressed....more

Federal Reserve Announces First Subscription Date of June 17, 2020 for the Term Asset-Backed Securities Loan Facility, Further...

On May 20, 2020, the Federal Reserve Board of Governors (the “Fed”) and the Federal Reserve Bank of New York (the “FRBNY”) announced the first subscription date of June 17, 2020 for funding under the Term Asset-Backed...more

CLOs and Term Asset-Backed Securities Loan Facility (TALF)—We’re Not That Desperate (Yet)

As revised, TALF may provide a safety net in the event of catastrophic CLO market conditions but is not likely to meet the goal of reviving the corporate loan market Introduction - On May 12, 2020, the Federal Reserve...more

Federal Reserve Releases Updated Term Sheet on the Term Asset-Backed Securities Loan Facility (TALF)

On April 9, 2020, the Federal Reserve Board of Governors (the “Fed”) released an updated term sheet (the “Updated Term Sheet”) for the Term Asset-Backed Securities Loan Facility (“TALF”) program.  While the Updated Term Sheet...more

Federal Reserve Establishes Term Asset-Backed Securities Loan Facility (TALF)

On March 23, 2020 the Federal Reserve Bank (the “Fed”) announced the establishment of the Term Asset-Backed Securities Loan Facility (the “TALF”) to “support the flow of credit to consumers and business” by facilitating the...more

DC Circuit Court Newsflash: “Transfer” means “Transfer”

In an eagerly anticipated (and much speculated upon) decision, a three judge panel of the United States Court of Appeals for the District of Columbia Circuit (“DC Circuit Court”) issued a unanimous opinion on Friday, February...more

“Risk Retentionizing” Your CLO: A Post-Effective Date Guide to Risk Retention Compliance

Over the last year and a half, asset managers of collateralized loan obligations (“CLO Managers”) have been focused on developing various strategies to enable them to comply with the retention requirements of the final U.S....more

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