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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

TALF CLO Update: The Fed Puts More Devil in its Details

The Fed releases more specifics and a start date for its Term Asset Backed Loan Facility (TALF) program, but overall the picture which emerges makes it less likely that the program will facilitate the flow of credit to US...more

Federal Reserve Announces First Subscription Date of June 17, 2020 for the Term Asset-Backed Securities Loan Facility, Further...

On May 20, 2020, the Federal Reserve Board of Governors (the “Fed”) and the Federal Reserve Bank of New York (the “FRBNY”) announced the first subscription date of June 17, 2020 for funding under the Term Asset-Backed...more

CLOs and Term Asset-Backed Securities Loan Facility (TALF)—We’re Not That Desperate (Yet)

As revised, TALF may provide a safety net in the event of catastrophic CLO market conditions but is not likely to meet the goal of reviving the corporate loan market Introduction - On May 12, 2020, the Federal Reserve...more

Federal Reserve Further Revises Term Sheet and Releases FAQ for the Term Asset-Backed Securities Loan Facility (TALF 2.0)

On May 12, 2020, the Federal Reserve Board of Governors (the “Fed”) and the Federal Reserve Bank of New York (the “FRBNY”) released an updated term sheet (the “New Term Sheet”) and Frequently Asked Questions (the “TALF FAQs”)...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

Risk Retention Reproposal’s Impact on CLOs: Loan Arrangers Get Invited to the Party that No One Wants to Attend

CLO managers and lead arrangers of syndicated loans received special attention in a proposal jointly released by six federal agencies to implement the credit risk retention requirements of Section 941 of the Dodd-Frank Act....more

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