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
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
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
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
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
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
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
7/21/2020
/ Amended Regulation ,
CFTC ,
Covered Funds ,
Credit Funds ,
Exclusions ,
FDIC ,
Federal Reserve ,
Financial Regulatory Agencies ,
Foreign Excluded Funds ,
Investment Schemes ,
OCC ,
Ownership Interest ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Venture Capital ,
Volcker Rule ,
Wealth Management
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
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
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
6/2/2020
/ Asset-Backed Securities ,
Business Development Companies ,
DBRS ,
Financial Markets ,
FRBNY ,
Investment Funds ,
Investment Management ,
KBRA ,
Loans ,
No-Action Letters ,
NRSRO ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
Term Asset-Backed Securities Loan Facility (TALF)
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
5/28/2020
/ Asset-Backed Securities ,
Borrowers ,
Capital Distributions ,
Certification Requirements ,
Collateral ,
Coronavirus/COVID-19 ,
Federal Loans ,
Federal Reserve ,
FRBNY ,
Issuer Eligibility Criteria ,
Master Loan and Security Agreement (MLSA) ,
Sponsors ,
Stock Repurchases ,
Term Asset-Backed Securities Loan Facility (TALF) ,
Term Sheets
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
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
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
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
12/19/2019
/ Assignments ,
Consumer Credit Protection ,
FDIC ,
Financial Regulatory Agencies ,
Financial Services Industry ,
Interest Payments ,
Loan Origination Funds ,
Madden v Midland Funding ,
National Bank Act ,
Non-Bank Lenders ,
OCC ,
Partnership Agreements ,
Preemption ,
Proposed Rules ,
Public Comment ,
Usury