Orrick's Financial Industry Week in Review

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Financial Industry Developments

SEC Extends Expiration Dates to Interim Final Rules Providing Exemptions for Certain Security-Based Swaps

On February 5, the SEC adopted amendments to the expiration dates in its interim final rules that provide exemptions under the securities laws for certain security-based swaps. Under the amendments, the expiration dates in the interim final rules will be extended to February 11, 2017. Release.

Financial Stability Oversight Council Announces Changes to Nonbank Designations as Systemically Important

On February 4, the Financial Stability Oversight Council (Council) today announced changes to certain practices relating to its process for reviewing nonbank financial companies for potential designation. Nonbank financial companies that are designated by the Council are subject to supervision by the Federal Reserve and enhanced standards. The Council will, amongst other things, inform companies earlier when they come under review and make available to the public additional information about its designations process. Release.

SEC Publishes Technical Corrections to Regulation AB II

On February 4, the SEC released certain technical corrections to rules that were published in the Federal Register on September 24, 2014. The changes effect Regulation AB and other rules governing the offering process, disclosure, and reporting for asset-backed securities. The corrections are effective February 6, 2015. Release.

FHFA Proposes Minimum Financial Eligibility Requirements for Fannie and Freddie Seller/Servicers

On January 30, the Federal Housing Finance Agency (FHFA) today proposed new minimum financial eligibility requirements for Fannie Mae and Freddie Mac Seller/Servicers. The proposed minimum financial requirements include net worth, capital ratio and liquidity criteria for the Enterprises' Seller/Servicers. FHFA is releasing the proposed criteria to provide greater transparency, clarity and consistency to industry participants and other stakeholders, and anticipates finalizing these requirements in the second quarter of 2015. Release.

Federal Reserve Proposes to Expand the Applicability of Board's Small Bank Holding Company Policy Statement

On January 29, Federal Reserve Board (Fed) invited public comment on a proposed rule to expand the applicability of the Board's Small Bank Holding Company Policy Statement (Policy Statement) for small bank holding companies as well as certain savings and loan holding companies. The Policy Statement facilitates the transfer of ownership of small community banks by allowing their holding companies to operate with higher levels of debt than would otherwise be permitted. Institutions subject to the Policy Statement are not subject to the Board's regulatory capital requirements. Currently, bank holding companies with less than $500 million in total consolidated assets may be subject to the Policy Statement. The proposed rule will permit to certain bank holding companies and savings and loan holding companies with less than $1 billion in total consolidated assets that meet the qualitative requirements to qualify. The Fed also adopted an interim final rule to exclude from the Fed's regulatory capital requirements savings and loan holding companies with less than $500 million in total consolidated assets that meet the qualitative requirements in the Policy Statement. Release. Policy Statement. Interim Final Rule.

Guidance on Private Student Loans With Graduated Repayment Terms Released

On January 29, federal financial regulatory agencies in partnership with the State Liaison Committee (SLC) of the Federal Financial Institutions Examination Council, issued guidance for financial institutions on private student loans with graduated repayment terms at origination. Graduated repayment terms are structured to provide for lower initial monthly payments that gradually increase. Financial institutions should provide disclosures that clearly communicate the timing and the amount of payments to facilitate a borrower's understanding of the loan's terms and features. Release. Guidance.

CFPB Issues Proposal To Facilitate Access To Credit In Rural And Underserved Areas

On January 29, the Consumer Financial Protection Bureau (CFPB) proposed several changes to its mortgage rules to facilitate lending in rural and underserved areas. The proposed rule would increase the number of financial institutions able to offer certain types of mortgages in rural and underserved areas. The proposed rule will be open for public comment until March 30, 2015. Release. Proposed Rule.

Rating Agency Developments

On February 6, Moody's restated its approach to rating trade receivables-backed transactions. Approach.

On February 5, S&P restated its criteria for rating global non-diversified auto dealer floorplan ABS. Criteria.

On February 4, DBRS requested comment for its methodology for rating CLOs and CDOs of large corporate credit. Proposal.

On February 3, S&P requested comment for its global rating methodology for rating CMBS. Proposal.

On February 2, DBRS released its methodology for rating U.S. wholesale securitizations. Methodology.

On January 29, Fitch released its global approach to developing criteria and models and assigning ratings. Approach.

On January 29, Fitch released an addendum to its rating criteria for rating covered bonds with respect to liquidity gap risks in public sector. Criteria.

On January 28, Kroll released its global methodology for rating banks and bank holding companies. Methodology.

Investment Management

The SEC's Office of Compliance Inspections and Examinations (OCIE) Publishes Risk Alert On Addressing Cybersecurity Issues for Broker-Dealers and Investment Advisers

On February 3, the SEC's Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert that contains observations based on examinations of more than 100 broker-dealers and investment advisers. The examinations focused on how these firms:

  • Identify cybersecurity risks
  • Establish cybersecurity policies, procedures, and oversight processes
  • Protect their networks and information
  • Identify and address risks associated with remote access to client information, funds transfer requests, and third-party vendors
  • Detect unauthorized activity

A second publication, an Investor Bulletin issued by the SEC's Office of Investor Education and Advocacy (OIEA), provides core tips to help investors safeguard their online investment accounts, including:

  • Pick a "strong" password
  • Use two-step verification
  • Exercise caution when using public networks and wireless connections

Risk Alert. Investor Bulletin. Press Release.

RMBS and Other Securities Litigation

Court Declines to Vacate Jury Verdict in Countrywide FIRREA Lawsuit

On February 3, Judge Jed S. Rakoff of the United States District Court of the Southern District of New York denied Bank of America Corporation's and Rebecca Mairone's motion for judgment as a matter of law, or, in the alternative a new trial. The jury found Bank of America and Mairone liable under the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA) for the sale of mortgage loans to Fannie Mae and Freddie Mac before the financial crisis. Judge Rakoff found that the jury's October 23, 2013 verdict was supported by sufficient evidence. Order.

ResCap Liquidating Trust Repurchase Lawsuit Survives Motion to Dismiss in Part

On February 3, Judge Martin Glenn of the United States Bankruptcy Court of the Southern District of New York denied defendants' motions to dismiss four adversary proceedings brought by the liquidating trust for Residential Capital LLC against several originators of residential mortgage loans. The court ruled that the ResCap Liquidating Trust was the real party in interest and therefore had standing to pursue claims against the originators for breach of representations and warranties. The defendants also argued that the Trust lacked standing to sue with regard to loans that had been securitized, because a predecessor ResCap entity had assigned its rights concerning those loans to third-parties. The court rejected this argument, holding that the scope of the assignments raised factual questions that could not be resolved at the motion to dismiss stage. The court granted defendants' motion to dismiss claims with respect to certain loans as time-barred, holding that New York's six-year statute of limitations expired as to all loans sold to ResCap prior to May 14, 2006 (six years before the adversary proceedings were filed). Finally, the Court declined to rule on the scope of the remedy available to the Trust at the pleading stage. Memorandum Opinion and Order.

S&P Settles RMBS Lawsuits for $1.375 Billion

On February 2, Standard & Poor's Ratings Services settled claims brought by the Department of Justice, 19 states and the District of Columbia related to credit ratings it issued and maintained for RMBS and CDOs before the financial crisis. As part of the settlement, it agreed to pay a total of $1.375 billion, with $687.5 million paid to the Department of Justice and $687.5 million to the states and District of Columbia. Settlement Agreement.

Also on February 2, S&P settled similar claims brought by the California Public Employees' Retirement System (CalPERS). The terms of that settlement agreement have not been made public.

JP Morgan Settles RMBS Lawsuit for $500 Million

On February 1, JP Morgan Chase & Co. settled federal securities claims brought by investors led by the Public Employees' Retirement System of Mississippi and the New Jersey Carpenters Health Fund related to Bear Stearns' sale of $17.58 billion in residential mortgage-backed securities. The settlement is subject to approval by U.S. District Judge Laura Taylor Swain of the United States District Court of the Southern District of New York. Settlement Agreement.

European Financial Industry Developments

The ECB Published a Recommendation on Dividend Distribution Policies

On January 28, the European Central Bank ("ECB") published a recommendation to establish dividend policies using conservative and prudent assumptions in order, after any distribution, to satisfy the applicable capital requirements.

The ECB has published recommendations with regard to Category 1, Category 2 and Category 3 credit institutions. Category 1 credit institutions should only distribute their net profits in dividends in a conservative manner to enable them to continue to fulfil all the Pillar 1 requirements. Category 2 credit institutions should not only distribute their net profits in dividends in a conservative manner but should also only pay out dividends to the extent which is consistent, at a minimum, with a linear path towards the fully loaded ratios required by the Common Equity Tier 1 capital ratio. Category 3 credit institutions which under the 2014 comprehensive assessment have a capital shortfall should, in principle, not distribute any dividend. Recommendation.

ECON Votes in Favor of the MIF Regulation

On January 27, the Economic and Monetary Affairs Committee ("ECON") released a press release stating that it had voted in favour of the proposed Regulation on multilateral interchange fees ("MIF Regulation"). This vote confirms an informal deal struck with the Council of Europe in December and will enforce a cap on the fees that banks can charge retailers for processing shoppers' payments.

The European Parliament as a whole is expected to vote on the deal at the second plenary session in April. Press Release.

ESMA Publishes an Opinion on Draft RTS on Clearing of Interest Rate Swaps under EMIR

Article 5(2) of Regulation (EU) No 648/2012 (EMIR) requires the European Securities and Markets Authority (ESMA) to develop draft regulatory technical standards specifying, inter alia, the class of OTC derivatives that should be subject to the clearing obligation, the date or dates from which the clearing obligation takes effect, including any phase in and the categories of counterparties to which the obligation applies.

In October 2014, ESMA submitted a draft regulatory technical standard (RTS) on the clearing obligation in respect of interest rate swaps to the European Commission. On 18 December 2014, the Commission submitted to ESMA a modified version of the RTS (the "modified RTS") introducing, among others, (1) amendments to the date on which the frontloading obligation starts to apply and (2) a new provision on the treatment of non-EU intragroup transactions. In the modified RTS, the Commission proposed that for a period of maximum three years, any third country shall be deemed equivalent within the meaning of Article 13(2) of EMIR. The effect would be to allow, for a period of three years, financial counterparties to apply for the intra-group exemption in respect of their transactions with any third-country entity in the absence of decisions on equivalence.

On January 29, ESMA published an opinion on the modified RTS stating that ESMA considers that the Commission's proposal in relation to non-EU intra group transactions is not appropriate from a legal perspective. ESMA noted that (i) the adoption by the Commission of implementing acts on equivalence under Article 13 is the only procedure envisaged under EMIR to establish whether third-countries can be considered as having legal, supervisory and enforcement frameworks equivalent to EMIR; and (ii)any provision that has an effect equivalent to that of an implementing act on equivalence under Article 13, although limited in time and scope, but without the examination procedure referred to in Article 13(2), may have unintended consequences and therefore requires a very careful review. ESMA will explore, in coordination with the Commission, a different manner to incorporate that provision. Opinion.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

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JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

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Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

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Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

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Contacting JD Supra

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Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

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