Robert Moyle

Robert Moyle

Orrick, Herrington & Sutcliffe LLP

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Latest Publications


National Bank Charters for Fintech Companies

"Technology-based products and services are the future of banking and the economy." "What excites me most about the changes occurring in financial services is the great potential to expand financial inclusion, reach...more

12/12/2016 - Bank Secrecy Act Banking Sector BSA/AML Consumer Financial Products Financial Services Industry FinTech Innovation Innovative Technology NYDFS OCC Popular Regulatory Oversight Trump Administration

Rating Agency Developments

On June 1, DBRS released its RMBS Insight 1.2: U.S. Residential Mortgage-Backed Securities Model and Rating Methodology. On June 1, Fitch released its U.S. RMBS Surveillance and Re-REMIC Criteria. On June 1, Moody’s issued...more

6/9/2015 - Asset-Backed Securities DBRS Fitch Moody's Mortgage-Backed Securities Non-Profits Rating Agencies RMBS S&P

SEC Provides Additional Analysis Related to Proposed Pay Ratio Disclosure Rules

On June 4, the Securities and Exchange Commission provided additional analysis related to its proposed rules for pay ratio disclosure. The staff believes that the analysis will be informative for evaluating the potential...more

6/9/2015 - Compensation & Benefits Executive Compensation Proposed Regulation Public Comment SEC Total Shareholder Return (TSR)

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

6/9/2015 - Dodd-Frank FDIC Federal Reserve Financial Institutions OCC Public Disclosure Stress Tests

Rating Agency Developments

On May 29, DBRS released its updated methodology for rating U.S. asset-backed commercial paper. On May 29, Fitch republished its criteria for rating supranationals. On May 28, Fitch released its updated criteria for rating...more

6/3/2015 - ABS Aircraft Asset-Backed Securities Canada CMBS DBRS Fitch KBRA Moody's Rating Agencies Reverse Mortgages Solar Energy Structured Finance

FHFA Releases Update on the Single Security Project

On May 15, the FHFA released an update on the structure of the Single Security, a project involving the development of a single mortgage-backed security that would be issued by Fannie Mae or Freddie Mac. The update contains...more

5/28/2015 - Fannie Mae FHFA Freddie Mac Mortgage-Backed Securities

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

5/28/2015 - Federal Reserve Financial Institutions HQLA Liquidity Coverage Ratio Municipal Bonds Securities

Fannie Mae and Freddie Mac to Issue New Seller/Servicer Eligibility Requirements

On May 20, the FHFA announced that Fannie Mae and Freddie Mac are issuing new finalized operational and financial eligibility requirements for mortgage seller/servicers. The updated requirements will be communicated through...more

5/28/2015 - Eligibility Fannie Mae FHFA Financial Institutions Freddie Mac Mortgage Servicers Popular Real Estate Market

Rating Agency Developments

On May 22, DBRS released its methodology for rating entities in the real estate industry. On May 21, DBRS released its methodology for reviewing ratings of Canadian structured finance and covered bond transactions. On May 20,...more

5/28/2015 - ABS Africa Aircraft Canada CMBS Covered Bonds DBRS EMEA EU Fitch Middle East Moody's Rating Agencies Real Estate Market Structured Finance

CFTC Issues Guidance for Swap Execution Facilities on the Calculation of Projected Operating Costs

On April 23, the CFTC issued guidance regarding the calculation of projected operating costs or expenses for the purpose of meeting the financial resource requirements under SEF Core Principle 13 in Section 5h(13) of the...more

4/28/2015 - CFTC New Guidance SEFs

Rating Agency Developments

On April 23, Fitch released its updated criteria for rating operational risk of U.S. servicers of RMBS and small balance commercial securities. On April 23, Fitch released its updated criteria for rating operational risk of...more

4/27/2015 - CMBS Collateralized Debt Obligations DBRS Fitch Moody's Rating Agencies RMBS Structured Financial Products Student Loans

Federal Reserve Board Releases Additional Information on the LISCC Supervisory Program

On April 17, the Federal Reserve Board published a Supervision and Regulation Letter containing additional information on the operating structure of the Large Institution Supervision Coordinating Committee (LISCC) supervisory...more

4/27/2015 - Banking Sector Federal Reserve Financial Institutions Supervision

CFTC Provides Relief in Connection with Erroneous Swap Trades and Swap Trade Confirmations

On April 22, the CFTC issued two no action letters providing relief intended to support the development of swap execution facilities (SEFs) and the trading of swaps on SEFs and designated contract markets (DCMs). The first no...more

4/27/2015 - CFTC DCMs No-Action Relief SEFs

FDIC Seeks Comment on Proposed Deposit Account Records Requirements for Large Banks

On April 21, the FDIC released an advanced notice of proposed rulemaking seeking comment on potential new recordkeeping standards for a limited number of FDIC-insured institutions with a large number of deposit accounts....more

4/27/2015 - Banking Sector Depository Institutions FDIC Recordkeeping Requirements Rulemaking Process

CFTC Issues Advisory on Reporting Obligations Pursuant to the Ownership and Control Final Rule

On March 23, CFTC Division of Market Oversight and Division of Swap Dealer and Intermediary Oversight issued a staff advisory to remind certain reporting parties (including futures commission merchants, clearing members,...more

4/2/2015 - Brokers CFTC Clearing Members DSIO FCMs Final Rules Reporting Requirements Swap Dealers

Rating Agency Developments

On March 25, S&P released its updated criteria for rating government-related entities. On March 25, Fitch released its updated criteria for rating commercial mortgage-backed securities (CMBS) in Asia-Pacific (APAC), including...more

4/2/2015 - Asia Pacific Banking Sector Canada CMBS DBRS Fitch Rating Agencies S&P

SEC Proposes Rule to Require Broker-Dealers Active in Off-Exchange Market to Become Members of National Securities Association

On March 25, the SEC proposed to narrow Rule 15b9-1 under the Securities Exchange Act, which exempts certain brokers or dealers from membership in a registered national securities association...more

3/31/2015 - Broker-Dealer Proposed Regulation Registration Requirement Rule 15B9-1 SEC Securities Exchange Act

SEC Adopts Rules to Facilitate Smaller Companies’ Access to Capital

On March 25, the SEC adopted final rules updating and expanding Regulation A, which provides an exemption from registration for smaller issuers of securities, to implement Title IV of the Jumpstart Our Business Startups...more

3/31/2015 - JOBS Act Regulation A SEC Small Business Small Offering Exemptions

CFPB Considers Stronger Consumer Protections for Payday Loans and Similar Debt

On March 26, the CFPB announced that it is considering stronger consumer protections relating to payday loans, vehicle title loans, deposit advance products, and certain high-cost installment loans and open-end loans. The...more

3/31/2015 - CFPB Consumer Financial Products Consumer Lenders Payday Loans Regulatory Agenda Title Loans

CFTC Solicits Public Comment on Swaps-Related Rulemakings in Response to U.S. District Court Order

On March 10, the CFTC issued a request for comment in response to an order issued by the U.S. District Court for the District of Columbia in the matter Securities Industry and Financial Markets Association, et al. v. United...more

3/13/2015 - CFTC Public Comment Rulemaking Process SIFMA Swaps

Rating Agency Developments

On March 9, Moody’s released its updated methodology for rating privately-financed public infrastructure (PFI/PPP/P3) projects. On March 9, Fitch released its updated criteria for rating single- and multi-name credit-linked...more

3/13/2015 - DBRS Fitch Moody's Public Private Partnerships (P3s) Rating Agencies

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

Regulation AB II – Final Rules

On August 27, 2014, the Securities and Exchange Commission unanimously voted to adopt a package of new and amended rules governing the registration, offering process, disclosure and reporting for SEC registered asset-backed...more

9/15/2014 - Asset-Backed Securities Disclosure Requirements Final Rules Market Participants Regulation AB Reporting Requirements SEC

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