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Rule 192

On January 25, 2023, the Securities and Exchange Commission (“SEC”) issued a release reproposing new Rule 192 (the “Proposed Rule”) under the Securities Act of 1933 (the “Securities Act”), which is intended to prevent the...more

Federal Reserve System Implements TALF 2.0 in Response to Coronavirus Disease 2019 (COVID-19) Crisis

On March 23, 2020, the Board of Governors of the Federal Reserve System (the “Board of Governors”) announced the implementation of a new Term Asset-Backed Securities Loan Facility (“TALF 2.0”) in order to provide liquidity...more

Risk Retention Update: Spring 2018

The “Risk Retention Rule” has been in effect for a little over two years for asset-backed securities (“ABS”) collateralized by residential mortgages, and for over one year for all other classes of ABS. While a general market...more

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