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TALF Program Update: Federal Reserve Releases Form of Agreed-Upon Procedures Report for CLOs

The form of agreed-upon procedures report provides additional clarity regarding certain TALF-required CLO report requirements. On September 1, 2020, the Federal Reserve released a form of agreed-upon procedures report...more

Regulators Gear Up for LIBOR Transition Testing

In anticipation of LIBOR discontinuation, key US and UK regulators signal a shift toward examining transition progress. After an initial phase of applying mostly verbal pressure, UK and US regulators are now taking a more...more

SEC Puts LIBOR Transition Testing in Focus

In anticipation of LIBOR discontinuation, the SEC will begin examining transition progress. Nearly a year after the US Securities and Exchange Commission’s (SEC’s) release of a Staff Statement on LIBOR Transition, the...more

Federal Reserve Releases Additional Information Regarding the Term Asset-Backed Securities Loan Facility

Updated FAQs and documentation provide additional information regarding the TALF program’s operations and dates for the first loans. On May 20, 2020, the Federal Reserve announced the TALF program’s first subscription date...more

Federal Reserve Releases Updated Term Asset-Backed Securities Loan Facility (TALF) Term Sheet

Updates and FAQs further expand the scope of the program and provide additional clarity regarding eligibility criteria and program requirements. On May 12, 2020, the Federal Reserve released an updated term sheet and FAQs,...more

Federal Reserve Expands Scope of New Term Asset-Backed Securities Loan Facility (TALF): Update

Certain commercial mortgaged-backed securities and collateralized loan obligations are now eligible. On April 9, 2020, the Federal Reserve announced it is taking additional actions to support further credit flow to...more

Federal Reserve Announces New Term Asset-Backed Securities Loan Facility (TALF) in Response to COVID-19

The new Term Asset-Backed Securities Loan Facility will support consumer and business access to credit through securitization. On March 23, 2020, in response to the financial uncertainty created by the COVID-19 pandemic,...more

LIBOR Discontinuation and Transition - What Investment Managers Should Know

The global shift away from LIBOR presents a complex, time-sensitive, multifaceted set of challenges and tasks for the investment management industry. In a statement published on July 12, 2019, the US Securities and...more

European Banking Authority Risk Retention Report – Key Guidance Still Missing

Annual report generally confirms EU risk retention rules but fails to provide guidance regarding originator special purpose entities - On 22 December 2014, the European Banking Authority (EBA) issued its report on...more

Final US Risk Retention Regulations Will Affect CLOs: Preliminary Thoughts On The New Regime

Contrary to many industry comments the new rules will require managers of open-market CLOS to retain risk. On October 21, 2014, six US federal regulators (the Agencies) began voting to adopt final rules implementing...more

EU Risk Retention Rules and CLOs – the Journey’s End?

Although the legislative process is now complete, the process of structuring CLO transactions to comply with the EU risk retention rules has just begun. The EU’s risk retention framework will come into effect next...more

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