Rick Jones

Rick Jones

Dechert LLP

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Complexity Is Not The Enemy

I’m getting pretty annoyed at the calumny heaped upon “complexity.” Everyone wants to “hit the ball down the middle of the fairway”; “keep it simple, stupid”; “Stick to the knitting…”; “Plain vanilla only, please.” Don’t...more

8/15/2014 - Capital Markets

A Mid-Year Report Card on the Commercial Real Estate Capital Markets

We at Crunched Credit have taken a bit of a pause of late. It is, of course, the dog days of summer. But it’s time to get back into the fray. Let’s start by noting the doldrums seem to have taken a pass. From where we...more

7/28/2014 - Capital Markets Commercial Real Estate Market Real Estate Market

Stand by for Risk Retention

The Risk Retention Rule Is Coming! The sky may not be falling, but The Risk Retention Rule is Coming at last! Very soon, we hear. ...more

7/3/2014 - Capital Markets Dodd-Frank Franken Amendment Rating Agencies Risk Retention SEC

Ribbet – The Green Cassandra of the Capital Markets

Moody’s published a piece the other week that analogized credit quality in the CRE capital markets to the boiling frog – that if you put a frog in cold water and slowly raise the temperature, it never jumps out until it,...more

5/28/2014 - Credit Ratings Moody's Rating Agencies

The Shadow: What’s in a Name – The Malifiscence of Shadow Banking

Long ago and far away, a radio show gave birth to the catchphrase “Who know what evil lurks in the hearts and minds of men? The Shadow knows.” I think, although I’m not entirely certain at this point, that the Shadow was a...more

5/22/2014 - Banks FSOC Shadow Banking

CRE Securitization: Rehabilitation Still In Progress

During the past several years, CRE Securitizations were airbrushed off the financial products reviewing podium like a discredited Politburo member. Not here, never ever here; nope, never heard of it. This was a mistake rooted...more

4/25/2014 - Collateralized Debt Obligations Collateralized Loan Obligations Commercial Real Estate Market Financial Products

EU Banks –Dog Bites Man, Again

The Financial Times reported on April 2 that the Eurozone Banks continue to load up on sovereign debt; generally, the debt of their respective host countries. A few days later, the Financial Times reported a bevy of talking...more

4/22/2014 - EU Eurozone Financial Times Foreign Banks Shadow Banking Sovereign Debt

Time for Regulatory Reset

It’s still in the early days of 2014. I think it’s finally stopped snowing in the East, the sun has come out and the stock market is continuing to outperform the woe purveyors. Republicans and Democrats have gotten...more

3/14/2014 - Banking Crisis Banking Sector Basel III Financial Regulatory Reform Proprietary Trading SIFIs Volcker Rule

REG AB: Channeling the Cheshire Cat

Regulation AB is big. Reg AB governs, among other things, the condition for shelf registration. The SEC is fixing to do something significant to Reg AB; we’re just not sure what....more

2/20/2014 - Compliance CREFC Dodd-Frank Regulation AB SEC

2014 Outlook

I have been mulling our 2014 Outlook for some time and decided to wait until after the New Year and CREFC to write. Just in case we got the whole Mayan calendar end of the world story wrong by a year (hey, it was 5000 years...more

1/31/2014 - Commercial Real Estate Market CREFC Financial Markets

Santa-baby: Volcker in the Sack

It’s the Christmas season and this week we got the Volcker Rule. How seasonably appropriate! Now, I get the whole Christmas trade. You’re good, you get toys; bad, coal in the stocking. But this is bad in a regifted,...more

12/16/2013 - Compliance Dodd-Frank Volcker Rule

Risk Retention Follies - Part Deux

Well, Halloween has come and gone and with the annual bacchanal of faux frisson over zombies, vampires and the like behind us, can we also put away risk retention anxieties like one of those annoying and morally disturbing...more

11/22/2013 - Capital Formation Commercial Real Estate Market FDIC Federal Reserve FHFA Financing HUD Investors Mortgages OCC Risk Retention SEC

European Sovereign Debt and the Clogging of the Banking System

Jens Weidmann, president of Deutsche Bundesbank, recently wrote a terrific piece in the Financial Times, making the point that the Faustian bargain between European sovereigns, their national banks, the ECB and EU...more

10/17/2013 - Banking Sector Banks EU European Central Bank Sovereign Debt

Budgets and Debt: The Cheshire Cat Apocalypse

Writing at the beginning of the week in which the government is supposed to run out of money, it's worth noting the cognitive dissidence between the political chattering classes who clogged the airways this weekend with...more

10/15/2013 - Government Shutdown

Risk Retention Re-proposal: The Good, Bad, Ugly And Unintended

The new Risk Retention Rule published jointly by the FDIC, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Securities Exchange Commission, with a little help from...more

10/8/2013 - FDIC Federal Reserve FHA HUD Qualified Mortgage Rule Risk Retention SEC

U.S. Basel III Final Rule and its Impact on the Securitization Framework

The three U.S. federal banking agencies (the “Agencies”) have adopted a final rule (the “Rule”) that implements the Basel III regulatory capital framework and comprehensively revises the regulatory capital requirements for...more

9/13/2013 - Banks Basel III Compliance Dodd-Frank New Regulations NPR Securitization

The European Bank Loan Trade Is Not Yet Done

Here at Dechert, we have seen a slow but steady work stream over the past several years in assisting institutions in either buying or selling of pools of financial assets. Just recently, we advised Wells Fargo Bank in...more

9/6/2013 - Banks EU Loans Trade Policy UK Wells Fargo

To The Barricades! (Again)

Out of the dimensionless emptiness of the information vacuum surrounding Dodd-Frank risk retention that enveloped us early this year, the word is now spreading, through what you might charitably describe as informal...more

8/7/2013 - Dodd-Frank Loans Mortgages Qualified Mortgage Rule Risk Management Risk Retention

The Consequences of a Failed Banking Union

I told the Blog team that I had sworn off writing about Europe for a while; but really. The FT opinionized last week that the EU ministerial decision to agree on a standard “bail-in” to fix broken European banks was a good...more

7/12/2013 - Bailout Banks Economic Downturn EU FDIC Foreign Banks

Why Does Everyone Want to Make Me Keep Thinking About Risk Retention

At last count, we now have four separate risk retention regimes (maybe five) that we need (or will soon need) to deal with as we attempt to restructure any securitization. They are, of course, all different. And let’s be...more

6/27/2013 - AIFMD Dodd-Frank European Banking Authority FDIC Risk Retention Safe Harbors Venture Capital

The Shadow Banking Market: The Shadow Knows

There’s a lot of talk these days about the growth of a shadow banking market. Shadow is right! The growth of the commercial lending market outside of the universe of insured depository institutions and life insurance...more

5/21/2013 - Banks Commercial Loans Financial Regulatory Reform Shadow Banking

Undue Commercial Real Estate Risks Are Bad: The Mathematical Proof of the Blindingly Obvious

I was entertaining myself early this morning by looking over a joint agency report just released entitled “An Analysis of the Impact of the Commercial Real Estate Concentration Guidance”. This report summarizes the...more

4/23/2013 - Banking Crisis CRE Portfolios Great Recession

Cyprus: Yesterday's News

As we predicted a few weeks ago (see link below), Cyprus has rapidly fallen off the screen. Back to business as usual, based upon an iron-willed refusal to see the spreading cracks in the edifice of the common market...more

4/17/2013 - Central Bank of Cyprus Cyprus Bailout EU European Commission

Terrorism Insurance Redux

Terrorism insurance has been boring for the past several years. It risks becoming not boring. In the lee of the terrorism attack of 9/11, the Terrorism Risk Insurance Act, or TRIA, was rapidly passed by the Congress and...more

4/3/2013 - Terrorism Insurance Terrorist Acts TRIA

Cyprus: Not the Archduke Ferdinand Moment, This Time

Among the more technical topics we cover in this Blog, we keep an eye on Europe as we fundamentally continue to worry that Europe’s disease could infect our markets. As I write this, Cyprus is trying to sort out the terms of...more

3/26/2013 - Bailout Banking Crisis EU

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