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Structured Finance Spectrum – February 2022

Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features analysis of how the market continues to swipe left on LIBOR but isn’t ready...more

New Proposed Registration Requirements for Covered Financial Products and Services Under the California Consumer Financial...

Last year, California passed the California Consumer Financial Protection Law (“CCFPL”), which renamed the Department of Business Oversight as the Department of Financial Protection and Innovation (“DFPI”) and expanded the...more

Application Deadline Looms Under California Debt Collection Licensing Act

On September 25, 2020, California Governor Gavin Newsom approved Senate Bill 908 – enacting the Debt Collection Licensing Act (DCLA). The DCLA, which takes effect January 1, 2022, requires a person or entity engaging in the...more

Structured Finance Spectrum – January 2021

Moving on from 2020 and building up for 2021. Read our Structured Finance Spectrum, covering safe harbors & remedies, CLOs & QMs, and passive & ESG investing, among other hot-topic issues in the structured finance markets in...more

State Regulators Enact Guidance Allowing Remote Work for Licensees Even After COVID-19

Our Financial Services & Products Group unpacks a pair of state rules that extend or make permanent regulations authorizing financial institutions to allow employees to work from home....more

New Jersey Releases Application Procedures for Student Loan Servicers

A&B ABstract: As we have previously discussed, effective November 27, 2019, Senate Bill 1149 (2019 N.J. Laws 200) (the “Act”), creates New Jersey’s “Student Loan Bill of Rights” and prohibits any person from “act[ing] as a...more

Louisiana Enacts Virtual Currency Company Law

A&B ABstract:  On June 13, Louisiana enacted a comprehensive new law imposing a licensing obligation on entities that engage in virtual currency business activity....more

Virginia Enacts Student Loan Servicing Law

A&B ABstract: On April 22, Virginia enacted a comprehensive new law imposing a licensing obligation on private student loan servicers and substantive restrictions on both private and federal student loan servicers....more

5/28/2020  /  Loan Servicer , Student Loans

New York Proposes Licensing Consumer Debt Collectors

A&B ABstract: On January 21, 2020, New York Governor Andrew Cuomo proposed a measure to license consumer debt collectors as part of his budget bill....more

Puerto Rico Office of the Commissioner of Financial Institutions Announces Mandatory Mortgage Servicer Reporting in Response to...

A&B Abstract: In the wake of the recent earthquakes in Puerto Rico, the Puerto Rico Office of the Commissioner of Financial Institutions (“OCFI”) released Circular Letter No. CFI-2020-01 (the “Circular Letter”). ...more

California Governor Moves to Strengthen State Consumer Protection Enforcement in 2020

A&B ABstract: On January 10, 2020, California Governor Gavin Newsom released his budget summary for 2020 to 2021. ...more

New York Overhauls Mortgage Loan Servicer Business Conduct Regulations

New York’s amended mortgage loan servicer regulations are a substantial departure from previous versions and could go beyond federal rules. Our Financial Services & Products Group delves into technicalities and ramifications...more

New York Proposes Guidance for Regulated Virtual Currency Licensees

A&B ABstract - Since the New York Department of Financial Services (“NYDFS”) finalized regulations for virtual currency firms in 2015, several regulated virtual currency licensees (“Licensees”) have sought permission to...more

New Jersey Requires License to Hold Mortgage Servicing Rights

A&B ABstract: New Jersey is the latest state to require the licensing of an entity that passively invests in whole residential mortgage loans on a servicing-released basis or in the servicing rights in such loans....more

Massachusetts Poised to Regulate Student Loan Servicers

A&B ABstract: Amid growing concerns of a student loan crisis, proposed Massachusetts H. 3977 is worth watching....more

Arizona Seeks to Improve FinTech Sandbox with HB 2177

A&B ABstract: Arizona launched a first-in-the-nation FinTech Sandbox in August 2018, which has been a successful venture by the state. ...more

New York Proposes Student Loan Servicing Rules

A&B ABstract - Amid growing concerns over the federal government’s “hands off” approach to regulating the student loan business, New York Governor Andrew Cuomo released 3 NYCRR 409, a proposed regulation aimed at providing...more

Nevada Adopts Regulations for Licensure by Endorsement

A&B Abstract: Nevada recently adopted new regulations allow a natural person to obtain a license by endorsement to engage in business as a mortgage broker or mortgage agent, mortgage loan servicer, or escrow agent or agency,...more

New Jersey Joins Other States Regulating Student Loan Servicers

A&B Abstract - New Jersey recently enacted its own version of a Student Loan Bill of Rights, which requires the licensing of any person acting “directly or indirectly” as a student loan servicer. ...more

Structured Finance Spectrum - July 2019

It’s hot out there and the market’s even hotter! Cool off with the latest issue of the Structured Finance Spectrum, our newsletter featuring what’s new and newsworthy in structured finance. ...more

New York DFS Launches Research and Innovation Division

A&B Abstract: In an effort to position itself as the “Regulator of the Future,” the New York State Department of Financial Services (“NYDFS”) recently launched the Research and Innovation Division, which will be responsible...more

Will Maine Begin to Regulate Passive, Secondary Market Investors in Student Loan Debt?

A&B Abstract:  Maine’s New Student Loan Bill of Rights requires the licensing of any person acting as “directly or indirectly” as a student loan servicer.  ...more

Structured Finance Spectrum - February 2019

SECURITIZATION SIDE NOTES – EU Risk Retention: Did This Come with a Gift Receipt? We’d Like to Return It - A new year brings new laws and regulations into effect, in this case a complicated and confusing gift from our...more

Structured Finance Spectre - October 2018

PRACTITIONER NOTES – Frankenstein’s Monster? Rosemary’s Baby? The Twins from the Shining? How Lenders are thinking about the Delaware Division Statute and Division LLCs - Recent amendments to the Delaware LLC Act (the...more

Structured Finance Spectrum - July 2018

REGULATORY REPORT – FASB’s New Current Expected Credit Loss Model - Sharpen your pencils and put on your green eyeshades – the Financial Accounting Standards Board is making major changes to the credit loss accounting...more

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