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
The U.S. commercial real estate market, valued at $20 trillion in 2021 by some estimates, touches nearly every facet of urban and suburban dwellers’ lives – from where they live (multi-family housing or apartment buildings)...more
ESG securitisation has the potential to play a key role in achieving sustainable finance objectives in the European Union. There have been a number of regulatory developments and other advances in this area, including the...more
Tim Conduit and Isabel Tinsley assess the key ESG-related milestones in the securitisation market and more widely. They highlight some key features of ESG-compliant securitisations and share their views on significant future...more
The Commercial Mortgage Market Since the Covid-19 Pandemic - The COVID-19 pandemic has caused disruption to many facets of what was once everyday life. As Americans sheltered in place, brick-and-mortar retail shopping and...more
Residential mortgage-backed securities offerings prior to 2008 gave rise to an abundance of litigation, some of which continues to this day. There may be reason to anticipate an increase in commercial mortgage-backed...more
The National Association of Insurance Commissioners (NAIC) Statutory Accounting Principles Working Group (SAPWG) met remotely on July 30, as part of the NAIC’s all-virtual 2020 Summer National Meeting....more
The global market for credit is estimated to be more than $200 trillion, approximately three times larger in aggregate than the global equity market. It consists of bank loans, sovereign and sub-sovereign debt, corporate...more
DOJ News & Litigation Updates - ITT Cannon to Pay $11 Million to Settle False Claims Allegations - ITT Cannon (ITT), a division of ITT Inc., has agreed to pay $11 million to settle whistleblower claims that it supplied...more
EU regulators announced today that they’ve been conducting an investigation into Amazon and “how it collects and uses data from third-party sellers who appear on the retailing giant’s website” with an eye to potential...more
Treasury Secretary Steven Mnuchin is the latest prominent government official to express concerns about Facebook’s coming Libra launch. Speaking at a briefing yesterday, Mnuchin focused on national security issues related to...more
On June 5, Fitch published a methodology for U.S. RMBS Seasoned and Reperforming Loans. Methodology....more
U.S. Financial Industry Developments - ISDA, AFME, ICMA, SIFMA and SIFMA AMG Publish Global Benchmark Report - The International Swaps and Derivatives Association (ISDA), the Association of Financial Markets in Europe...more
On June 19, 2018, Fitch published its rating criteria for U.S. Federal Family Education Loan Program Student Loan ABS. On June 19, 2018, Fitch published its rating criteria for EMEA CMBS....more
An effective program is a key corporate function of increasing importance. It can be a competitive advantage, creating a tone of excellence which permeates the firm’s culture, products, services and customer relations....more
On August 8, 2017, the Federal Reserve Board and Federal Deposit Insurance Corp. extended the deadline for 19 foreign banks and two domestic bank holding companies to file their next round of "living wills" detailing how they...more
On July 7, 2017, Kroll published its Research Recap for Q2 2017. Here are several articles of interest: ABS: KBRA Comments on Alitalia Extraordinary Administration Request - AVIATION: 2017 Update Aircraft leasing...more
Financial Industry Developments - CFTC Proposes to Amend Rules Governing Chief Compliance Officer Duties and Annual Reports for Certain Registrants - On May 3, 2017, the U.S. Commodity Futures Trading Commission...more
Rating Agency Developments - On April 19, 2017, Fitch issued a report entitled Airport Operating Lease ABS Rating Criteria. On April 14, 2017, Fitch issued a report entitled North America and Asia-Pacific...more
Financial Industry Developments - CFPB Proposes to Provide Flexibility in Collecting Information - On March 24, 2017, the Consumer Financial Protection Bureau ("CFPB") released a proposal to amend Equal Credit...more
On March 29, 2017, Moody’s published its approach to assessing credit risk for multilateral development banks and other supranational entities. Report. On March 28, 2017, DBRS published its methodology for rating...more
Financial Industry Developments - House Committee on Financial Services Comments on OCC Fintech Charter - All 34 Republican members of the Financial Services Committee of the U.S. House of Representatives, including...more
Financial Industry Developments - Federal Reserve Board Announces Finalized Rule Adjusting the Board's Maximum Civil Money Penalties - On January 18, 2017, the Federal Reserve Board announced that it was adjusting...more
Financial Industry Developments - Prohibition on Dealing or Investing in Industrial or Commercial Metals - On January 3, 2017, the Office of the Comptroller of the Currency (the "OCC") finalized a rule that...more
Financial Industry Developments - CTFC Approves Re-Proposal of Position Limits Regulation - On December 5, 2016, the U.S. Commodity Futures Trading Commission ("CFTC") unanimously approved to re-propose rules that...more