Rick Jones

Rick Jones

Dechert LLP

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The Grand Illusion: A Strategy

Have you heard the following thought expressed recently in one way or the another, “I’m less worried about what new black swans might swim onto our screens and more worried that we will just wake up one day, peer out of our...more

10/6/2014 - Financial Markets

Liquidity Coverage Ratio Rule: Birds Gotta Fly, Fish Gotta Swim…and Regulators Gotta Regulate

With apologies to Jerome Kern and Oscar Hammerstein, and in the afterglow of a relatively amiable final AB Rule, we are reminded this week that our business remains hogtied to a regulatory establishment that can’t seem to...more

9/24/2014 - Basel III Final Rules Liquidity Coverage Ratio OCC Regulation AB SEC

Final REG AB Rules: Man Bites Dog

I am congenitally pessimistic and some have, shockingly, called me cynical. Early last week, while we waited for Reg AB, I would have bet more than a dollar that there would have been a number of things in this final Rule...more

9/5/2014 - Asset-Backed Securities Disclosure Requirements Final Rules NRSRO Public Offerings Rating Agencies Regulation AB Reporting Requirements SEC

New Regulation AB II and NRSRO Rules Released

The U.S. Securities Exchange Commission (the “SEC”) released new Regulation AB II Rules (the “Reg AB Rules”) and regulations relating to credit rating agencies (“the NRSRO Rules”) on August 27, 2014. The Reg AB Rules1 revise...more

9/5/2014 - Asset-Backed Securities Disclosure Requirements New Regulations NRSRO Public Offerings Rating Agencies Regulation AB Reporting Requirements SEC

Man the Barricades (Or the Bleachers) – Reg AB Is Here

As I write this, we are awaiting SEC’s vote scheduled for tomorrow, August 27, on final Regulation AB2 Rule and the NRSRO Rules. I say “man the barricades or the bleachers” because I’m not sure whether there is much to do...more

8/27/2014 - Compliance Enforcement NRSRO Regulation AB SEC

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

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