Orrick's Financial Industry Week In Review

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U.S. Financial Industry Developments

CFTC Staff Issues Interpretive Guidance Regarding Exemption from Aggregation

On May 2, 2018, the Commodity Futures Trading Commission's ("CFTC") Division of Market Oversight issued a CFTC staff letter with interpretive guidance regarding CFTC Regulation 150.4(b)(1), an exemption from position aggregation requirements for certain commodity pool investors. According to the staff letter, an institutional investor is not required to look through its investment in a fund to aggregate commodity investment positions of an underlying portfolio company in which such investor may hold a 10% or greater indirect interest when such investor qualifies for the Regulation 150.4(b)(1) exemption from position aggregation. Press Release. Staff Letter

 

Rating Agency Developments

On May 2, 2018, Fitch published a report entitled: Germany Residential Mortgage Rating Criteria Addendum. Release.

On May 2, 2018, Fitch published a report entitled: Switzerland Residential Mortgage Rating Criteria Addendum. Release.

On May 2, 2018, DBRS published a report entitled: Rating Credit Funds. Release.

On May 1, 2018, Fitch published a report entitled: EMEA RMBS Rating Criteria. Release.

On April 26, 2018, Moody's published its methodology for rating Banks. Release.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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