The Return of TALF Fund Opportunities Via COVID-19 Relief
Corporate CLO issuers, regardless of whether they are organized onshore or offshore, should generally be exempt from Corporate Transparency Act reporting requirements, although onshore CLO co-issuers will likely be subject to...more
In September 2023, the Structured Finance Association (SFA) published its ESG Best Practices for Auto Asset-Backed Securities (ABS) and Residential Mortgage-Backed Securities (RMBS) Disclosures. The industry-wide working...more
Securities and Exchange Commission Chairman Jay Clayton issued a public statement October 30, 2019, seeking market input on the asset-level disclosure requirements for SEC-registered residential mortgage-backed securities...more
The fallout from the last financial crisis and recession is far from over. More than a decade after the demise of Lehman and Bear Stearns, among others, litigation continues related to alleged deficiencies in mortgage loans...more
U.S. Financial Industry Developments - CFTC and SEC Announce Approval of New MOU - On June 28, 2018, the Commodity Futures Trading Commission ("CFTC") and the Securities and Exchange Commission ("SEC") announced that...more
It's official. Risk retention became effective for residential mortgage-backed securities (“RMBS”) on December 24, 2015. Since the final rules (the “Rules”) were issued, there has been a lot of talk throughout the broader...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
In October 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, the Federal Housing...more
When Congress passed the Dodd-Frank Act, it mandated the creation of risk retention rules in an effort to align the incentives of sponsors of asset-backed securities (ABS) with the interests of investors and to improve the...more
On January 7, Fitch revised its criteria for rating U.S. Public Finance Short-Term Debt. On January 7, DBRS released its methodology for surveillance of North American CMBS. On January 6, Fitch released its global criteria...more
On October 21 and 22, the Fed, HUD, FDIC, FHFA, OCC, and SEC jointly approved final risk retention rules. The final rules, which implement Section 941 of Dodd Frank, generally follow the re-proposed rules issued in August...more
On October 21-22, 2014, the federal regulatory agencies responsible for implementing regulations under The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) finalized rules for risk retention...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
ESMA Publishes Guidelines on the EU Implementation of CPSS-IOSCO Principles - On September 4, ESMA published the translation of guidelines and recommendations on implementing the principles for financial market...more
No Intervention for Class of Homeowners in Suit Against HSBC - On August 25, 2014, Judge Denise Cote of the U.S. District Court for the Southern District of New York denied a motion brought by a class of putative...more