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FHFA Requests Input on FHFA’s Draft Strategic Plan for Fiscal Years 2018-2022

On September 27, 2017, the Federal Housing Finance Agency requested comment on its proposed strategic plan, which “…reflects the Agency’s priorities as regulator of the Federal Home Loan Bank System and as regulator and...more

10/6/2017  /  Comment Period , Fannie Mae , FHFA , Freddie Mac

Agencies Propose Simplifying Regulatory Capital Rules

On September 27, 2017, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the Office of the Comptroller of the Currency announced a proposed rule intended to decrease regulation under these entities’...more

CFTC’s Division of Market Oversight Extends Existing Relief and Provides Additional Relief for Reporting Parties From Reporting...

On September 25, 2017, the Division of Market Oversight of the U.S. Commodity Futures Trading Commission “issued a no-action letter (CFTC Staff Letter 17-45) that extends current relief and provides additional relief to...more

10/5/2017  /  CFTC , Final Rules , No-Action Letters , OCR

Community Reinvestment Act Regulations: Notice of Proposed Rulemaking

On September 22, 2017, multiple government agencies announced “… a proposed rule that would revise their regulations implementing the Community Reinvestment Act (CRA) (12 USC 2901 et seq.). The proposed rule would amend the...more

10/5/2017  /  CRA , HMDA , Loans , Mortgages

FDIC Adopts Final Rule on Qualified Financial Contracts

On September 27, 2017, the Federal Deposit Insurance Corporation finalized a rule, similar to the rule approved by the Federal Reserve Board, relating to termination and cancellation rights for specified contracts and...more

Rating Agency Developments

On September 26, 2017, Moody’s issued a report entitled Proposed Update to the Banks Rating Methodology. On September 26, 2017, Moody’s issued a report entitled Banks....more

10/3/2017  /  DBRS , Moody's , Rating Agencies

Agencies to Propose Amending CRA Regulations to Conform to HMDA Regulation Changes, and Remove References to the Neighborhood...

On September 13, 2017, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly released proposed changes to each agency’s...more

9/21/2017  /  FDIC , HMDA , Mortgages , OCC

Rating Agency Developments

On September 13, 2017, DBRS issued a report entitled Third-Party Due Diligence Criteria for U.S. RMBS Transactions. On September 13, 2017, Fitch issued a report entitled Fitch Updates Future Flow Securitisation Criteria;...more

9/19/2017  /  DBRS , Fitch , KBRA , Rating Agencies

Rating Agency Developments

On August 2, 2017, DBRS issued a report entitled: North American Commercial Mortgage Servicer Evaluations. Report. On July 31, 2017, Fitch issued a release entitled: Fitch Updates UK Whole Business Securitisation Rating...more

CFTC Staff Extends Time-Limited No-Action Relief on the Applicability of Transaction-Level Requirements in Certain Cross-Border...

On July 25, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) “issued a time-limited no-action letter that extends relief to swap dealers [] registered with the CFTC that are established under the laws of...more

8/4/2017  /  CFTC , No-Action Relief , Swap Dealers , Swaps

Federal Regulatory Agencies Announce Coordination of Reviews for Certain Foreign Funds Under “Volcker Rule”

On July 21, 2017, the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, the Office of Comptroller of the Currency and the Securities and...more

8/3/2017  /  CFTC , FDIC , Federal Reserve , OCC , SEC , Volcker Rule

SEC Issues Investigative Report Concluding DAO Tokens, a Digital Asset, Were Securities

On July 25, 2017, the Securities and Exchange Commission (the “SEC“) released a report indicating that many offerings of “digital assets[,]” such as those using “distributed ledger or blockchain technology,” could be subject...more

Rating Agency Developments

On July 26, 2017, Moody’s issued the following reports: Moody’s Approach to Rating Credit Card Receivables-Backed Securities - Moody’s Approach to Rating Asset-Backed Commercial Paper... ...more

8/1/2017  /  CMBS , Fitch , Moody's , Rating Agencies

Federal Reserve Board Announces Guidelines for Banking Entities Seeking an Extension to Conform Certain “Seeding” Investments in...

On July 24, 2017, the Federal Reserve Board “announced guidelines for banking entities seeking an extension to conform certain ‘seeding’ investments in hedge funds or private equity funds (‘covered funds‘) to the requirements...more

Rating Agency Developments

On June 7, 2017, Fitch issued a report entitled Fitch Publishes Updated U.S. Timeshare Loan ABS Rating Criteria. Press Release. On June 6, 2017, Fitch issued a report entitled Fitch Updates Structured Finance CDOs...more

6/13/2017  /  Fitch , KBRA , Moody's , Rating Agencies

Federal Reserve Board Approves Extended Transition Period for Deutsche Bank AG, SVB Financial Group, and UBS Group AG to Conform...

On June 7, 2017, the Federal Reserve Board authorized an extension of up to five (5) years for Deutsche Bank AG, SVB Financial Group, and UBS Group AG to comply with certain aspects of the Dodd-Frank Wall Street Reform and...more

Rating Agency Developments

On April 6, 2017, Fitch issued a report entitled Fitch: Early Signs are Positive for Risk Retention in U.S. CMBS. Release....more

4/18/2017  /  CMBS , Fitch , Rating Agencies , Risk Retention

Exemptions for Security-Based Swaps

On February 10, 2017, the Securities and Exchange Commission (SEC) extended to February 11, 2018 the expiration dates of certain interim final rules relating to “exemptions under [various securities laws] for those...more

2/24/2017  /  Dodd-Frank , SEC , Security-Based Swaps , Swaps

CFTC’s Division of Swap Dealer and Intermediary Oversight Issues Time-Limited No-Action Transition for March 1, 2017 Compliance...

On February 13, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) announced that, between March 1, 2017 and September 1, 2017, it would “not recommend an enforcement action against a swap dealer (SD) for...more

Rating Agency Developments

On February 15, 2017, DBRS issued a report entitled North American Single-Asset/Single-Borrower Methodology. On February 15, 2017, DBRS issued a report entitled DBRS Commercial Real Estate Property Analysis Criteria....more

2/23/2017  /  DBRS , Fitch , Rating Agencies

Rating Agency Developments

On January 18, 2017, Moody’s issued a report entitled Hybrid Equity Credit. Report. On January 17, 2017, DBRS issued a report entitled Rating North American CMBS Interest-Only Certificates – Request for Comment. Report....more

1/26/2017  /  CMBS , DBRS , Fitch , Moody's , Rating Agencies

FHFA Requests Public Input on Duty to Serve Program

On January 18, 2017, the Federal Housing Finance Agency (the “FHFA“) announced its request for public comment on (i) proposed chattel loan pilot initiatives for Fannie Mae and Freddie Mac and (ii) the expectations and...more

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 its maximum civil money penalty limits, pursuant to federal law, to accommodate for inflation....more

CFTC Unanimously Approves Proposals on Swaps Data and Other Amendments

On January 13, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) approved two rules: one relating to access to swaps data and one relating to disciplinary actions. The CFTC is accepting comments on the proposed...more

1/25/2017  /  CFTC , Proposed Amendments , Swaps

SEC Announces 2017 Examination Priorities

On January 12, 2017, the Securities and Exchange Commission released the 2017 examination priorities for its Office of Compliance Inspections and Examinations. The categories of interest “include electronic investment advice,...more

1/24/2017  /  Investment Adviser , OCIE , SEC
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