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Replacing LIBOR in Derivatives Transactions: A Complex Undertaking

The London interbank offered rate (LIBOR), the submission of which will cease to be mandated by the U.K. Financial Conduct Authority in 2021 as a result of concerns over its reliability and robustness due to its lack of...more

The New Delaware LLC “Divisive Merger” Provision – A Potentially Dangerous Loophole Under Debt Covenants

Effective August 1, 2018, the Delaware Limited Liability Company Act (the Delaware LLC Act) allows a Delaware limited liability company (an LLC) to divide into two or more LLCs and allocate the assets, liabilities, rights and...more

Opportunistic CDS Strategies Available to CDS Protection Sellers Part II: McClatchy and Sears

In this second part, we analyze two recent situations where a proposed refinancing dramatically affected the CDS market for the reference entity because of the reduction in the sell-side risk. Although these cases may or may...more

6/7/2018  /  CDS , Refinancing , Sears

Opportunistic CDS Strategies Available to CDS Protection Sellers Part I: An Introduction

Over the past few years, the CDS market has seen an increase in activism and the evolution of creative refinancing and restructuring strategies intended to achieve particular outcomes in the CDS market....more

Comptroller of the Currency Announces That Leveraged Lending Guidance Is Not Expected to Be Changed

On May 24, 2018, Joseph Otting, the comptroller of the currency, the principal regulator of all national banks, announced in a telephonic press conference that he does not expect that the Office of the Comptroller of the...more

CDS Market Integrity After Hovnanian

In a companion piece, we reviewed the recent federal district court decision in Solus Alternative Asset Management LP v. GSO Capital Partners L.P. (SDNY Jan. 29, 2018)....more

LIBOR Replacement to Begin Publication

The Alternative Reference Rate Committee (ARRC) of the New York Federal Reserve Bank announced that the Secured Overnight Financing Rate (SOFR), a broad Treasury repo financing rate that is the ARRC’s recommended alternative...more

Unconventional CDS Credit Events: Hovnanian Enterprises

Introduction Over the past few years, a number of issuers in financial distress and their investors have used refinancing and restructuring strategies that capitalize on credit default swap (CDS) contracts written on the...more

Small Business Credit Availability Act Becomes Law, Allowing BDCs to Incur Significantly More Debt

On March 23, 2018, President Trump signed into law the Consolidated Appropriations Act of 2018, which contains as Title VIII thereof the Small Business Credit Availability Act. ...more

Comptroller of the Currency Announces That OCC Will Not Enforce Leveraged Lending Guidance

On Feb. 27, 2018, Joseph Otting, the comptroller of the Currency, the principal regulator of all national banks, speaking at a conference hosted by the Structured Finance Industry Group in Las Vegas, NV, announced that the...more

SEC Approves NYSE Rule Changes on Listing Without an IPO

The Securities and Exchange Commission (SEC) has approved a proposal by the New York Stock Exchange (NYSE) to facilitate listing on the NYSE without a prior underwritten public offering. Section 102.01B of the NYSE Listed...more

Funds Talk: February 2018

Global Regulators Increasingly Shifting Focus to Cryptocurrency - After years of allowing cryptocurrency transactions to fly under the radar, financial market regulators are beginning to turn their attention to virtual...more

SEC Releases Guidance on Near-Term Disclosure Regarding Effects of New Tax Law

The tax reform signed into law by President Trump on Dec. 22 (the Tax Act) presents public companies with several accounting and disclosure challenges. Although companies are still evaluating how they will be affected by the...more

The Limitations on Interest Deductibility in the New Tax Law

On Dec. 20, 2017, the House of Representatives by a vote of 224 to 201 passed the most significant tax legislation in more than three decades. The Senate passed the same legislation earlier in the day....more

Funds Talk: October 2017 - MiFID II – State of Play

On Jan. 3, 2018, the long-anticipated overhaul of European Union (EU) financial markets legislation will come into effect. The second Markets in Financial Instruments Directive (MiFID II) will broaden the scope of EU...more

Debt Dialogue: June 2017 - SEC Proposes Modifications to Rule 15c2-12 to Increase Event-Driven Disclosures by Municipal Issuers

Disclosure in the municipal securities markets has been a focus of the Securities and Exchange Commission for some time, but it has recently returned to center view with the SEC’s proposals for additions to the event-driven...more

Funds Talk: June 2017 - FINRA Expands Margin Rules for Mortgage-Backed Securities Transactions

FINRA has introduced an expansion of Rule 4210 (the Rule), effective Dec. 15, 2017, importing margin concepts into the world of mortgage-backed transactions. ...more

Funds Talk: April 2017

SEC Offers Guidance on ‘Fast-Growing Trend’ of Robo-Advisers - As technology and robo-advisers become increasingly common options for asset managers and investors alike, the SEC is taking a closer look at some of the...more

Debt Dialogue: March 2017

Kramer Levin’s Debt Dialogue addresses recent developments and recurring issues that debt-focused investors commonly encounter in connection with enforcement of rights, interpretation of documentation and other relevant...more

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