In a complex securitization structure, determining the identity of the sponsor under the credit risk retention rules can be a daunting task. Introduction Under the credit risk retention rules adopted pursuant to the...more
The U.S. Securities and Exchange Commission (SEC) recently adopted amendments (Amendments) to remove references to credit ratings in Rule 2a-7 under the Investment Company Act of 1940, as amended (1940 Act), the primary rule...more
On October 22, 2014, six federal agencies approved a final rule requiring sponsors of asset securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the...more
Six federal agencies approved on October 22 a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall...more
Although regulators have rebuffed industry efforts to have tender option bonds (TOBs) exempted from the final credit risk retention rule (the CRRR), they have nevertheless provided some helpful changes and clarifications that...more
On October 21 and 22, the Fed, HUD, FDIC, FHFA, OCC, and SEC jointly approved final risk retention rules. The final rules, which implement Section 941 of Dodd Frank, generally follow the re-proposed rules issued in August...more
Call to Action: The final risk retention rules will change the status quo for nearly all CLO managers beginning in the fourth quarter of 2016. All managers should begin assessing whether and how they will comply with the...more
On October 21-22, 2014, the federal regulatory agencies responsible for implementing regulations under The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) finalized rules for risk retention...more
On October 22, 2014, the federal regulatory agencies responsible for implementing regulations under Dodd-Frank finalized the risk retention rules for ABS transactions, including CMBS transactions. The final rules come more...more
Senior Fed Officials Encourage Financial Industry Firms to Improve Compliance Culture - Enhancing culture was the theme at a workshop on “Reforming Culture and Behavior in the Financial Services Industry” held at the...more
After three years of waiting, we now have our Risk Retention Rule. All six of the Agencies responsible for the Rule – the FDIC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the...more
Contrary to many industry comments the new rules will require managers of open-market CLOS to retain risk. On October 21, 2014, six US federal regulators (the Agencies) began voting to adopt final rules implementing...more
On October 22, 2014, six federal agencies adopted the final Credit Risk Retention Rule under Section 941 of the Dodd-Frank Act. The final rule will require sponsors of securitizations to retain an economic interest in the...more
In February 2014, the Securities and Exchange Commission (SEC) once again re-opened the comment period with respect to proposed revisions to Regulation AB relating to the disclosure of asset-level data after receiving many...more