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Rating Agency Developments

On November 14, 2017, DBRS published its global methodology for rating finance companies. Release. On November 14, 2017, Fitch updated its U.S. RMBS seasoned, re-performing, and nonperforming loan criteria. Release....more

Prohibition on Dealing or Investing in Industrial or Commercial Metals

On January 3, 2017, the Office of the Comptroller of the Currency (the “OCC“) finalized a rule that prohibits national banks and federal savings associations from dealing or investing in industrial or commercial metals. An...more

Federal Banking Agencies Finalize an 18-Month Examination Cycle for Small Banking Institutions

On December 12, 2016, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board and the Office of the Comptroller of the Currency (OCC) finalized rules that generally allow well-capitalized and well-managed...more

The OCC Proposes Rule to Address Concerns Relating to Exercise of Default Rights Under Qualified Financial Contracts

On October 3, 2016, the Office of the Comptroller of the Currency proposed a rule to enhance the resilience of federally chartered and licensed financial institutions. The proposed rule addresses concerns relating to the...more

The CFPB Publishes Final Rule for Prepaid Accounts

On October 5, 2016, the Consumer Financial Protection Bureau (the “CFPB”) finalized comprehensive consumer protections for prepaid account users that require, among other things, financial institutions to limit consumer...more

Proposed Rule to Address Concerns Relating to Exercise of Default Rights Under Qualified Financial Contracts

On October 3, 2016, the Office of the Comptroller of the Currency proposed a rule to enhance the resilience of federally chartered and licensed financial institutions. The proposed rule addresses concerns relating to the...more

Rating Agency Developments

On May 27, 2016, S&P published its revised rating criteria for hedge fund securitizations.  Report. On May 26, 2016, Fitch published its revised sovereign rating criteria.  Report. On May 26, 2016, DBRS published its...more

Agencies Propose Net Stable Funding Ratio Rule

On May 3, 2016, the Federal Deposit Insurance Corporation, the Federal Reserve and the Office of the Comptroller of the Currency proposed a rule, the net stable funding ratio (the “NSFR”), to strengthen banks by requiring...more

Rating Agency Developments

On May 3, 2016, DBRS published its rating methodology for pooled aircraft lease securitizations. Report. On May 3, 2016, DBRS published its master U.S. ABS surveillance methodology. Report. On May 3, 2016, S&P published its...more

No-Action Letter Issued Regarding the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the ownership and control final rule (the “OCR Final Rule”). The OCR Final Rule requires...more

FHFA, Fannie Mae and Freddie Mac Announce Independent Dispute Resolution Program

On February 2, the Federal Housing Finance Agency (the “FHFA”) announced that Fannie Mae and Freddie Mac have implemented an independent dispute resolution process for resolving repurchase disputes. The process would allow...more

Rating Agency Developments

On October 8, Fitch published a report clarifying the application of its United Kingdom RMBS criteria during the ongoing consultation period. On October 12, DBRS published a report describing its methodology for generation of...more

CFTC Announces Further Extension of Time-Limited No Action Relief

On October 14, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight (the “Division”) announced further extension of the time-limited no action relief for swaps executed as part of a package...more

Rating Agency Developments

On October 1, DBRS published its U.S. RMBS rating methodology. On October 1, DBRS published its rating methodology for European consumer and commercial ABS transactions. On October 1, DBRS published its methodology for rating...more

CFTC’s Division of Market Oversight Provides Additional Time to Comply with Electronic Reporting Requirements in the OCR Final...

On September 28, the U.S. Commodity Futures Trading Commission’s (the “Commission”) Division of Market Oversight issued a no-action letter that provides reporting parties additional time to comply with certain reporting...more

Rating Agency Developments

On September 24, DBRS published a report describing its approach for monitoring European CMBS ratings. On September 25, DBRS published its methodology for rating European RMBS transactions issued in Europe with residential...more

SEC Seeks Public Comment on Regulation S-X

On September 25, the U.S. Securities and Exchange Commission (the “SEC”) announced that it is seeking public comment on the effectiveness of financial disclosure requirements in Regulation S-X. The request for comments...more

SEC Proposed to Amend Rules Governing its Administrative Proceedings

On September 24, the U.S. Securities and Exchange Commission (the “SEC”) proposed to amend rules governing its administrative proceedings. Key changes to the SEC’s rules of practice include: adjustment of timing of the...more

OCC Released Update to the Bank Accounting Advisory Series

On September 29, the Office of the Comptroller of the Currency released an update to the Bank Accounting Advisory Series (the “BAAS”). The goal of the BAAS is to promote consistent application of accounting standards among...more

CFTC Announces to Issue Award of Approximately $290,000 to Whistleblowers

On September 29, the U.S. Commodity Futures Trading Commission announced that it would issue an award of approximately $290,000 to whistleblowers for providing valuable information about violations of the Commodity Exchange...more

CFTC Approves National Futures Association Rules Enhancing Protections for Retail Forex Customers

On August 27, 2015, the U.S. Commodity Futures Trading Commission (CFTC) approved rule amendments and a new interpretive notice proposed by the National Futures Association (NFA). The rule amendments and interpretive notice...more

Rating Agency Developments

On August 27, 2015, Fitch updated its criteria for analyzing large loans in U.S. CMBS transactions. On August 28, 2015, Fitch updated its UK Whole Business Securitization rating criteria. On August 28, 2015, Fitch updated its...more

Rating Agency Developments

On July 28, DBRS published methodology for conducting operational risk assessments for U.S. asset-backed securities originators. On July 28, 2015, DBRS published methodology for conducting operational risk assessments for...more

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

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

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