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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

Some Good News for the Loan Industry—Loans Are Not Securities

Although the loan industry has long looked at loans as being obligations that arise in a commercial lending relationship, which are therefore not securities under Federal and state securities laws, the law supporting this...more

CLOs Under the Volcker Rule: New Exemptions, New Issues, New Obligations

Under the final version of the Volcker Rule issued this week, issuers and sponsors of new CLO issuances should consider structuring CLOs to conform to the exclusions contained in the rule, and banks and bank affiliates that...more

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