Sean Solis

Sean Solis

Dechert LLP

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Fed Issues Additional Guidance on Extended Conformance Period – Be Careful What You Ask For

A few steps forward and a giant leap back. This familiar phrase might be the perfect summary of the CLO market’s Volcker Rule roller coaster since December 2013. A few weeks ago we wrote about the Federal Reserve Board’s...more

5/2/2014 - Banks Collateralized Loan Obligations Federal Reserve Volcker Rule

Federal Reserve Extends Volcker CLO Compliance Period

On April 7th the Federal Reserve Board (the “Fed”) announced that it would provide banking entities with two additional one-year extensions to conform their ownership of CLOs covered by the Volcker Rule. The Fed stated that...more

4/14/2014 - Banks Collateralized Loan Obligations Federal Reserve Financial Markets Time Extensions Volcker Rule

CLOs under the Volcker Rule: New Exemptions, New Issues, New Obligations – Part I

Befitting the holiday season the regulators recently decided to bestow upon us all the much anticipated (dreaded?) Volcker Rule. At 1100 pages of truly riveting reading material, Volcker has certainly given all of us plenty...more

2/11/2014 - Banks Collateralized Debt Obligations Dodd-Frank Proprietary Trading Trust Preferred Securities Volcker Rule

The recently finalized "Bad Actor" rules and their applicability to CLO transactions

Section 926(1) of the Dodd-Frank Act required the Securities and Exchange Commission (“SEC”) to adopt rules that disqualify securities offerings involving certain felons and other “bad actors” from reliance on Rule 506 under...more

10/25/2013 - Bad Actors Dodd-Frank Felons JOBS Act Regulation D Rule 506 Offerings SEC Securities Act of 1933

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

On August 28, 2013, six federal regulatory agencies (among them, the SEC, Federal Reserve, OCC and the FDIC (collectively, the “Agencies”)) released a 499 page second risk retention proposal (the “Second Proposal”). The...more

9/19/2013 - FDIC Federal Reserve Loan Servicer Loans OCC Risk Retention SEC

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