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Term SOFR is Here - The ARRC Recommends CME Group’s Term SOFR Rates for Use

An update from the Dechert LIBOR taskforce - On July 29, 2021, the Alternative Reference Rates Committee (the “ARRC”) formally recommended the forward-looking term rates based on the secured overnight financing rate (“SOFR”)...more

Dechert on LIBOR – Officially the Beginning of the End

On Friday, 5 March 2021, the Financial Conduct Authority (FCA) announced that all 35 LIBOR benchmark settings as currently published by ICE Benchmark Administration (IBA), the administrator of LIBOR, will either cease to be...more

Dechert on LIBOR – A New Year Special

2020 was a busy year for global benchmark transition, and the coronavirus pandemic did little to slow the pace. The end of 2020 saw an unexpected development that caused the market to pause – the potential delay of the...more

Dechert on LIBOR - A New Year Special

2020 was a busy year for global benchmark transition, and the coronavirus pandemic did little to slow the pace. The end of 2020 saw an unexpected development that caused the market to pause – the potential delay of the...more

Term Asset-backed Securities Loan Facility (“TALF”) Funds Resources

Why is TALF a good opportunity? Simply put, based on TALF 1.0 (the initial version of the program in effect during 2009–2010), we expect there to be in excess of 100 new TALF funds established as part of TALF 2.0 in 2020,...more

TALF 2.0 Extended Through 2020 and Other Updates

With the Term Asset-Backed Securities Loan Facility program (“TALF 2.0”) officially underway and open to investors, the Federal Reserve Bank of New York (the “FRBNY”) continues to modify the program, most recently granting an...more

Federal Agencies Adopt Amendments to Volcker Rule

The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures Trading...more

FRBNY, Yet Again, Revises the TALF 2.0 Frequently Asked Questions

Introduction - As the reinstated Term Asset-Backed Securities Loan Facility program (“TALF 2.0”) opened, the Federal Reserve Bank of New York (the “FRBNY”) continues to revise the TALF 2.0 program details, changing the...more

Federal Regulators to the Rescue? The OCC Adopts Rule to Address Madden Risk

In an effort to address the uncertainty created by the U.S. Second Circuit Court of Appeal’s holding in Madden v. Midland Funding, on May 29, 2020, the Office of the Comptroller of the Currency (OCC) adopted a final rule...more

FRBNY Further Revises TALF 2.0 FAQs; SEC Issues No-Action Relief for Registered Fund and BDC Participants

Introduction - As market participants prepare for the launch of the latest version of the Term Asset-Backed Securities Loan Facility (“TALF”) program (“TALF 2.0”), two new developments provide greater clarity as to how the...more

Federal Reserve Announces First Subscription Date of June 17, 2020 for the Term Asset-Backed Securities Loan Facility, Further...

On May 20, 2020, the Federal Reserve Board of Governors (the “Fed”) and the Federal Reserve Bank of New York (the “FRBNY”) announced the first subscription date of June 17, 2020 for funding under the Term Asset-Backed...more

Federal Reserve Further Revises Term Sheet and Releases FAQ for the Term Asset-Backed Securities Loan Facility (TALF 2.0)

On May 12, 2020, the Federal Reserve Board of Governors (the “Fed”) and the Federal Reserve Bank of New York (the “FRBNY”) released an updated term sheet (the “New Term Sheet”) and Frequently Asked Questions (the “TALF FAQs”)...more

Federal Reserve Releases Updated Term Sheet on the Term Asset-Backed Securities Loan Facility (TALF)

On April 9, 2020, the Federal Reserve Board of Governors (the “Fed”) released an updated term sheet (the “Updated Term Sheet”) for the Term Asset-Backed Securities Loan Facility (“TALF”) program.  While the Updated Term Sheet...more

Federal Reserve Establishes Term Asset-Backed Securities Loan Facility (TALF)

On March 23, 2020 the Federal Reserve Bank (the “Fed”) announced the establishment of the Term Asset-Backed Securities Loan Facility (the “TALF”) to “support the flow of credit to consumers and business” by facilitating the...more

Federal Regulators to the Rescue? The OCC and FDIC Propose Rules to Address Madden Risk.

With the hope of finally addressing the uncertainty created by the U.S. Second Circuit Court of Appeal’s holding in Madden v. Midland Funding,1 the Office of the Comptroller of the Currency (OCC) and the Federal Deposit...more

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