Daniel Colaizzi

Daniel Colaizzi

Dechert LLP

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Latest Publications


US Treasury Eyes Online Marketplace Lending

In an interesting and unusual development, the Treasury Department has issued a notice seeking public input on the online marketplace lending business for small businesses and consumers (“Notice”), setting forth 14 questions...more

8/25/2015 - Non-Bank Lenders Notice and Comment Online Marketplace Lending Preemption Risk Retention U.S. Treasury Usury

Risk Retention Realized – Potential Solutions for CLO Market Participants

In anticipation of the effective date of the Final Rule on December 24, 2016 (early Christmas gift?), CLO market participants have been constructing solutions that allow collateral managers to raise the capital necessary to...more

8/12/2015 - Collateralized Loan Obligations Market Participants Risk Retention

The Rise of the C-MOA

Since the release of the final U.S. risk retention rule (the “Final Rule”) in October 2014, CLO market participants have been grappling with its ramifications and working to devise solutions that permit collateral managers to...more


U.S. Risk Retention Final Rule: Capitalized Manager Vehicles, Majority Owned Affiliates and Other FAQs

Since its initial release we have received numerous inquiries from market participants (clients and non-clients alike) concerning the meaning and ramifications of the final U.S. risk retention rule (the “Final Rule”) on...more

1/27/2015 - Collateralized Loan Obligations Final Rules Market Participants Risk Retention

Coal in Your CLO Stocking: U.S. Risk Retention Effective Date

The federal regulatory agencies responsible for implementing regulations under The Dodd-Frank Wall Street Reform and Consumer Protection Act finalized rules for risk retention requirements in CLO transactions (the “Final...more

12/24/2014 - Collateralized Loan Obligations Dodd-Frank Final Rules Risk Retention

U.S. Risk Retention Final Rule: Playing it Forward for CLOs

We will leave the hand wringing and teeth gnashing to others. We expect there will be a lot of that in the days ahead. We have had our say on the misguided premises and tortured statutory interpretation underpinning the final...more

10/23/2014 - Collateralized Debt Obligations Collateralized Loan Obligations Dodd-Frank FDIC Risk Retention Securities Exchange Act Volcker Rule

Fed Issues Additional Guidance on Extended Conformance Period – Be Careful What You Ask For

A few steps forward and a giant leap back. This familiar phrase might be the perfect summary of the CLO market’s Volcker Rule roller coaster since December 2013. A few weeks ago we wrote about the Federal Reserve Board’s...more

5/2/2014 - Banks Collateralized Loan Obligations Federal Reserve Volcker Rule

Federal Reserve Extends Volcker CLO Compliance Period

On April 7th the Federal Reserve Board (the “Fed”) announced that it would provide banking entities with two additional one-year extensions to conform their ownership of CLOs covered by the Volcker Rule. The Fed stated that...more

4/14/2014 - Banks Collateralized Loan Obligations Federal Reserve Financial Markets Time Extensions Volcker Rule

The recently finalized "Bad Actor" rules and their applicability to CLO transactions

Section 926(1) of the Dodd-Frank Act required the Securities and Exchange Commission (“SEC”) to adopt rules that disqualify securities offerings involving certain felons and other “bad actors” from reliance on Rule 506 under...more

10/25/2013 - Bad Actors Dodd-Frank Felons JOBS Act Regulation D Rule 506 Offerings SEC Securities Act of 1933

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