David Ridenour

David Ridenour

Orrick, Herrington & Sutcliffe LLP

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CFTC Approves Final Rule on Residual Interest Deadline for Futures Commission Merchants

On March 17, the U.S. Commodity Futures Trading Commission (Commission) unanimously approved a final rule removing the December 31, 2018 automatic termination of the phased-in compliance period for the Residual Interest...more

3/24/2015 - CFTC FCMs Final Rules Residual Interest

Treasury Departments State Small Business Credit Initiative Releases Quarterly Report

On March 19, the U.S. Treasury Department’s State Small Business Credit Initiative (SSBCI) released a new Quarterly Report detailing how the program continues to help small businesses grow and create jobs. More than $1.1...more

3/24/2015 - Equity Financing Finance Lenders Quarterly Report Small Business U.S. Treasury

HUD and Census Bureau Announce New Residential Construction Activity in February

On March 19, the U.S. Department of Housing and Urban Development (HUD) and the U.S. Census Bureau jointly announced the following new residential construction statistics for February 2015: (i) BUILDING PERMITS: Privately...more

3/24/2015 - Affordable Housing Census Bureau Construction Industry HUD

CFPB Launches Public Inquiry to Inform Agency Review of the Credit Card Market

On March 17, the Consumer Financial Protection Bureau (CFPB) announced it is seeking public comment on how the credit card market is functioning and the impact of credit card protections on consumers and issuers. This public...more

3/24/2015

FHFA Report Details Progress on the 2014 Strategic Plan for Fannie Mae and Freddie Mac Conservatorships

On March 16, the  FHFA issued a Progress Report on the initiatives outlined in the 2014 Strategic Plan for the Conservatorships of Fannie Mae and Freddie Mac and the 2014 Conservatorship Scorecard. The Progress Report...more

3/24/2015 - Fannie Mae FHFA Freddie Mac

Rating Agency Developments

Moody’s released its approach to rating securities backed by wireless towers....more

3/24/2015 - Cell Towers Moody's Securities Wireless Industry

Comptroller of the Currency Discusses Tailoring Supervisory Expectations to the Size and Complexity of Regulated Institutions

On March 19, the Comptroller of the Currency, Thomas Curry, discussed the Office of the Comptroller of the Currency’s approach to tailoring regulatory and supervisory expectations to the size and complexity of supervised...more

3/24/2015 - Banking Sector CoC Congressional Investigations & Hearings Financial Institutions Supervision

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

Rating Agency Developments

On February 23, DBRS releases its Criteria for Guarantees and other forms of explicit support....more

3/3/2015 - DBRS Rating Agencies

FHFA House Price Index Shows Increases for Fourteen Consecutive Quarters

On February 26, the FHFA House Price Index showed that U.S. house prices rose 1.4 percent in the fourth quarter of 2014. This marked the fourteenth consecutive quarterly price increase in the purchase-only, seasonally...more

3/2/2015 - FHFA Housing Market

SEC Chair and European Union Financial Services Commissioner Meet

On February 26, the SEC Chair Mary Jo White hosted a meeting with European Union Financial Services Commissioner Jonathan Hill. Chair White and Commissioner Hill discussed the importance of international cooperation in...more

3/2/2015 - EU Financial Markets Financial Services Authority Global Market Jonathan Hill Mary Jo White SEC

CFTC Reopens Comment Periods

On February 24, the CFTC submitted for publication in the Federal Register a notice reopening the comment periods for the two Position Limit rulemakings, in anticipation of questions and comments that may arise from the...more

3/2/2015 - CFTC Rulemaking Process

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

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

Michael Brickman Named Deputy Comptroller for Special Supervision

On January 26, 2015 Michael Brickman was named Deputy Comptroller for Special Supervision at the OCC. As Deputy Comptroller of Special Supervision, Mr. Brickman will oversee the supervision of the OCC’s most critical problem...more

1/30/2015 - Administrative Appointments

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