The Return of TALF Fund Opportunities Via COVID-19 Relief
On April 26, 2023, the United States Court of Appeals for the Second Circuit affirmed the dismissal of two actions brought by issuers of collateralized debt obligations (“CDOs”) against the trustee and master servicer of...more
On August 2, 2022, the Financial Industry Regulatory Authority, Inc. (“FINRA”) proposed to amend FINRA Rule 6730(a)(1) (the “FINRA Proposal”) to reduce the Trade Reporting and Compliance Engine (“TRACE”) reporting timeframe...more
FINRA recently filed a proposed rule change with the US Securities and Exchange Commission (SEC) on November 12, 2021 that would seek to once again delay the effective date of changes to FINRA Rule 4210 that were previously...more
On April 9, 2020, the Federal Reserve Bank of New York (the Federal Reserve) announced updates to the 2020 Term Asset-Backed Securities Loan Facility (TALF). The updates include expanding the eligible underlying asset classes...more
Prior to the open of markets in the U.S. on March 25th, the Federal Reserve announced that it is committed to using its full range of tools to address the coronavirus pandemic. The steps announced by the Federal Reserve...more
Today, the Federal Reserve Bank announced several unprecedented emergency measures, including unlimited purchases of Treasury and agency mortgage-backed securities, three new lending facilities, and expansion of two programs...more
Mortgage-backed and asset-backed securities are beginning to feel the effects of quarantines and social distancing as people spend – and earn – less money. Our Finance Group explores the basic disclosures to consider with any...more
Earlier this month, staff of the Securities and Exchange Commission (SEC) published guidance that encourages market participants to move away from LIBOR (the Staff Statement). The interest benchmark rate is expected to...more
A recent action where the SEC focused on the presumably conservative undervaluation of assets suggests that it is more than willing to use valuation as a hook to deter “smoothing” of returns. As we previously noted, while the...more
Withholding tax rates on income derived from Eurobonds and lease certificates issued outside of Turkey, on interest payments of Tier II loans and securitization financings; as well as BITT applicable to securitizations backed...more
Imagine a perfect world where every financial transaction has an electronic chain of proof of title and a history of all prior owners. This is the world of blockchain technology – a world that already exists for Bitcoin, and...more
The reproposed amendments to Rule 4210 attempt to address commenters’ concerns that the original proposed rule would impact business activity in the TBA market....more
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
On October 22, 2014, six federal agencies approved a final rule requiring sponsors of asset securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the...more
Six federal agencies approved on October 22 a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall...more
The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Department of Housing and Urban Development, Federal Housing Finance Agency, and...more
On October 22, 2014, the federal regulatory agencies responsible for implementing regulations under Dodd-Frank finalized the risk retention rules for ABS transactions, including CMBS transactions. The final rules come more...more
On September 9, the CFTC issued an exemptive letter, which provides relief from certain provisions of Regulations 4.7(b) and 4.13(a)(3) restricting marketing to the public. The exemptive letter harmonizes these rules with...more
On August 27, 2014, following years of preparation, speculation and comment, the Securities and Exchange Commission (SEC) adopted Regulation AB II (Reg AB II). Reg AB II represents a response to requirements of Sections 939A...more
On June 13, Moody’s announced that its private student loan default rate index will continue to decline. On June 13, Fitch announced that it has taken various conforming rating actions on enhanced municipal bonds and...more
ESMA Reports on Information that Competent Authorities Should Provide to it Under the AIFMD - The European Securities and Markets Authority (ESMA), has published a final report of technical advice for the European...more
The SEC settled public administrative proceedings against a registered investment adviser (the “Adviser”) over (i) its exercise of discretion in valuing securities held by a privately offered fund the Advised managed (the...more
One of the important unfinished aspects of the Dodd-Frank Act (“Act”) is the requirement for Federal agencies (“Regulators”) to issue regulations implementing Section 941 of the Act which generally requires that a securitizer...more