David Ridenour

David Ridenour

Orrick, Herrington & Sutcliffe LLP

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Latest Publications


OCC Names First Ever Chief Risk Officer

On August 6, the OCC named Linda Cunningham as its first Chief Risk Officer. Ms. Cunningham will lead the agency’s newly created Office of Enterprise Risk management and will report directly to the Comptroller of the...more

8/12/2015 - Administrative Appointments Banking Sector OCC Risk Management

SEC Adopts Registration Rules for Security-Based Swap Dealers and Major Security-Based Swap Participants

On August 5, the SEC proposed new rules to provide a comprehensive, efficient process for security-based swap dealers and major security-based swap participants to register with the SEC. The new rules address all aspects of...more

8/12/2015 - Federal Register Financial Markets Registration Requirement SEC Security-Based Swaps Swap Dealers

SEC Adopts Rule for Pay Ratio Disclosure

On August 5, the SEC adopted a final rule that requires a public company to disclose the ratio of the compensation of its CEO to the median compensation of its employees. The new rule was mandated by the Dodd-Frank Wall...more

8/11/2015 - CEOs Disclosure Requirements Dodd-Frank Executive Compensation Pay Ratio Publicly-Traded Companies Reporting Requirements SEC

CFPB Study Finds Electronic Mortgage Closings Can Benefit Consumers

On August 4, the CFPB published a report on its “Know Before You Owe” eClosing project which found that borrowers can benefit from electronic closings when navigating the mortgage closing process. Specifically, the results of...more

8/11/2015 - Borrowers CFPB Closing Documents Consumer Lenders Electronic Filing Financial Institutions Financial Services Industry Homeowners Lenders Mortgage Lenders Mortgage Servicers Mortgages Real Estate Market

Rating Agency Developments

On August 5, Moody’s released is approach to rating Railcar leasing ABS....more

8/11/2015 - Credit Rating Agencies Moody's Rating Agencies

CFPB Sues Offshore Payday Lender

On August 4, the CFPB announced the filing of a lawsuit against NDG Eneterprise, a complex web of commonly controlled companies, for collecting money consumers did not owe. The CFPB alleges that the defendants illegally...more

8/11/2015 - Borrowers CFPB Consumer Lenders Financial Institutions Financial Services Industry Lenders Offshore Companies Payday Loans

Comptroller Discusses Efforts to Ease Regulatory Burden on Community Banks

On August 5, the Comptroller of the OCC addressed efforts to ease the burden of regulation on community national banks and federal savings associations....more

8/11/2015 - Banking Sector Banks Community Banks Federal Savings Associations Financial Institutions Financial Regulatory Reform Financial Services Industry OCC

Madden v. Midland Funding, LLC

On May 22, the Second Circuit Court of Appeals ruled that when a nonbank entity purchases loans from a national bank, the interest rate the nonbank entity may charge is limited to the rate of interest of the state of...more

7/14/2015 - Appeals Banking Sector Banks Financial Institutions Interest Rates Loans Midland Funding National Bank Act Nonbank Firms Preemption Repurchases

Rating Agency Developments

On June 1, DBRS released its RMBS Insight 1.2: U.S. Residential Mortgage-Backed Securities Model and Rating Methodology. On June 1, Fitch released its U.S. RMBS Surveillance and Re-REMIC Criteria. On June 1, Moody’s issued...more

6/9/2015 - Asset-Backed Securities DBRS Fitch Moody's Mortgage-Backed Securities Non-Profits Rating Agencies RMBS S&P

SEC Provides Additional Analysis Related to Proposed Pay Ratio Disclosure Rules

On June 4, the Securities and Exchange Commission provided additional analysis related to its proposed rules for pay ratio disclosure. The staff believes that the analysis will be informative for evaluating the potential...more

6/9/2015 - Compensation & Benefits Executive Compensation Proposed Regulation Public Comment SEC Total Shareholder Return (TSR)

FDIC, Federal Reserve and Office of Comptroller of the Currency Reiterate Annual Public Disclosure Requirements for Medium-Sized...

On June 2, the Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve System and Office of the Comptroller of the Currency reiterated the disclosure requirements for annual stress tests conducted by...more

6/9/2015 - Dodd-Frank FDIC Federal Reserve Financial Institutions OCC Public Disclosure Stress Tests

Rating Agency Developments

On May 29, DBRS released its updated methodology for rating U.S. asset-backed commercial paper. On May 29, Fitch republished its criteria for rating supranationals. On May 28, Fitch released its updated criteria for rating...more

6/3/2015 - ABS Aircraft Asset-Backed Securities Canada CMBS DBRS Fitch KBRA Moody's Rating Agencies Reverse Mortgages Solar Energy Structured Finance

FHFA Releases Update on the Single Security Project

On May 15, the FHFA released an update on the structure of the Single Security, a project involving the development of a single mortgage-backed security that would be issued by Fannie Mae or Freddie Mac. The update contains...more

5/28/2015 - Fannie Mae FHFA Freddie Mac Mortgage-Backed Securities

Federal Reserve Proposes Adding Additional Asset Types to Meet LCR Requirements

On May 21, the Federal Reserve Board proposed adding certain general obligation state and municipal bonds to the range of assets a banking organization may use to satisfy the Liquidity Coverage Ratio (LCR) requirements...more

5/28/2015 - Federal Reserve Financial Institutions HQLA Liquidity Coverage Ratio Municipal Bonds Securities

Fannie Mae and Freddie Mac to Issue New Seller/Servicer Eligibility Requirements

On May 20, the FHFA announced that Fannie Mae and Freddie Mac are issuing new finalized operational and financial eligibility requirements for mortgage seller/servicers. The updated requirements will be communicated through...more

5/28/2015 - Eligibility Fannie Mae FHFA Financial Institutions Freddie Mac Mortgage Servicers Popular Real Estate Market

Rating Agency Developments

On May 22, DBRS released its methodology for rating entities in the real estate industry. On May 21, DBRS released its methodology for reviewing ratings of Canadian structured finance and covered bond transactions. On May 20,...more

5/28/2015 - ABS Africa Aircraft Canada CMBS Covered Bonds DBRS EMEA EU Fitch Middle East Moody's Rating Agencies Real Estate Market Structured Finance

SEC and FINRA to Hold National Compliance Outreach Program for Broker-Dealers

On May 12, the SEC and FINRA announced the opening of registration for their 2015 National Compliance Outreach Program for Broker-Dealers. The program is intended to provide an open forum for regulators and industry...more

5/15/2015 - Broker-Dealer Chief Compliance Officers FINRA Professional Conferences SEC

Delinquencies, Foreclosures and Bankruptcies Improve as Household Debt Stays Flat

On May 12, The Federal Reserve Bank of New York’s Household Debt and Credit Report revealed that aggregate household debt balances were largely flat in the first quarter of 2015. At of the end of March, total household...more

5/15/2015 - Information Reports

Rating Agency Developments

On May 7, DBRS published a report on it methodology for rating U.S. Timeshare Loan Securitizations....more

5/15/2015 - DBRS Rating Agencies Securitization Vehicles

Director of FDIC Submits Resignation

On May 8, the Director of the FDIC Jeremiah O. Norton submitted his resignation, effective Jun 5, 2015. Norton has served as Director since April 16, 2012....more

5/15/2015 - Administrative Resignation FDIC

CFPB Finalizes Rule Aimed at Improving Credit Card Agreement Submission Process

On April 15, the CFPB issued a final rule aimed at improving the way that companies submit consumer credit card agreements to the CFPB....more

4/20/2015 - CFPB Credit Card Agreements Final Rules

Federal Reserve Request Comment on Proposed Amendments to Regulation D

On April 13, the Federal Reserve Board requested public comment on proposed amendments to Regulation D (Reserve Requirements of Depository Institutions) making technical changes to the calculation of interest payments on...more

4/20/2015 - Banks Federal Reserve Proposed Amendments Public Comment Regulation D

Rating Agency Developments

On April 16, Fitch published a report on Pennsylvania State System of Higher Education, PA....more

4/20/2015 - Fitch Rating Agencies

SEC Adopts Updated EDGAR Filer Manual

On April 13, the SEC adopted revisions to EDGAR Filer Manual and related rules to reflect updates to the EDGAR system. The updates are being made primarily to support the 2015 US GAAP financial reporting and 2015 EXCH...more

4/20/2015 - EDGAR Issuers Publicly-Traded Companies SEC

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