On January 25, 2023, the United States Securities and Exchange Commission (the SEC) revived a proposed rule (initially proposed in September 2011) pursuant to Section 27B (Proposed Rule 192) aimed at preventing material...more
Demand for Narrowbody Aircraft Exceeds the Available Supply- Outside of Asia, summer travel has seen a large recovery and this has coincided with a large uptick in demand for narrowbody aircraft by both airlines and...more
On June 25, 2020, five federal agencies (the “Agencies”) finalized amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more
Financial Industry Developments - Fee Rate Advisory #3 for Fiscal Year 2017 - On May 31, 2017, the Securities and Exchange Commission ("Commission") announced that starting July 4, 2017, the fee rates applicable to most...more
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
On October 20, the SEC revised EDGAR filer manual to reflect certain changes related to asset-backed security filings....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
In this issue: - In preliminarily denying two exemption requests, the SEC takes a stand for market transparency in ETFs and upholds the arbitrage mechanism that allows market prices to closely track NAVs. -...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
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
On August 27, 2014, the Securities and Exchange Commission (the “SEC”) adopted two final rules implementing new regulations affecting asset-backed securities (“ABS”). The first set of rules, referred to in this memorandum as...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