The Return of TALF Fund Opportunities Via COVID-19 Relief
The U.S. Department of the Treasury requires U.S. issuers—including U.S.-domiciled investment funds1—to report foreign residents’ holdings of U.S. securities every five years on its Treasury International Capital (TIC) Form...more
Corporate CLO issuers, regardless of whether they are organized onshore or offshore, should generally be exempt from Corporate Transparency Act reporting requirements, although onshore CLO co-issuers will likely be subject to...more
Culminating a four-year-long process, a key working group of insurance regulators has adopted new standards for determining whether an investment held by an insurance company should be characterized as a “bond” evidencing a...more
On August 2, 2022, the Financial Industry Regulatory Authority, Inc. (“FINRA”) proposed to amend FINRA Rule 6730(a)(1) (the “FINRA Proposal”) to reduce the Trade Reporting and Compliance Engine (“TRACE”) reporting timeframe...more
Insurers and others are closely following efforts by the National Association of Insurance Commissioners (NAIC) to develop a new, comprehensive, “principles-based” definition of debt securities for purposes of insurers’...more
The Situation: The Volcker Rule's complexity has created uncertainty and compliance burdens that adversely affect market liquidity, risk hedging, and other economically important activities. The Opportunities: Bank...more
The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC) data reporting system. Form SHC is the mandatory five-year...more
Form Deadline Is March 3, 2017 - Introduction - The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC)...more
Marketplace loans are the most exciting securitization asset class to emerge since credit cards and student loans. Securitization provides marketplace loan investors with liquidity, diversified funding and interest rate...more
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,...more
On September 9, the CFTC issued an exemptive letter, which provides relief from certain provisions of Regulations 4.7(b) and 4.13(a)(3) restricting marketing to the public. The exemptive letter harmonizes these rules with...more
On August 27, 2014, following years of preparation, speculation and comment, the Securities and Exchange Commission (SEC) adopted Regulation AB II (Reg AB II). Reg AB II represents a response to requirements of Sections 939A...more
On August 27, 2014, the Securities and Exchange Commission unanimously voted to adopt a package of new and amended rules governing the registration, offering process, disclosure and reporting for SEC registered asset-backed...more
On August 27, the Securities and Exchange Commission at an open meeting unanimously adopted Regulation AB II (Reg AB II). The final rule provides significant revisions to Regulation AB, which provides the rules regarding the...more
On August 27, 2014 the Securities and Exchange Commission (the “SEC”) approved final rules relating to asset-backed securities (“ABS”) disclosure and registration (the “Final Rules”). The Final Rules are contained in a final...more
I am congenitally pessimistic and some have, shockingly, called me cynical. Early last week, while we waited for Reg AB, I would have bet more than a dollar that there would have been a number of things in this final Rule...more
The U.S. Securities Exchange Commission (the “SEC”) released new Regulation AB II Rules (the “Reg AB Rules”) and regulations relating to credit rating agencies (“the NRSRO Rules”) on August 27, 2014. The Reg AB Rules1 revise...more
The SEC announced that it adopted new rules and rule amendments (collectively, the “Final Rules”) that revise the offering process, disclosure and reporting requirements for publicly-offered asset-backed securities (“ABS”). ...more
The Securities and Exchange Commission today adopted final amendments related to Regulation AB that were first proposed in 2010.1 The changes address the offering process and disclosure and periodic reporting requirements for...more
The U.S. Department of the Treasury requires U.S. resident issuers (including U.S. resident investment funds) and investment advisers managing foreign investment funds to report foreign residents’ holdings of U.S. securities,...more
On December 10, 2013, five U.S. financial regulators (the Agencies) adopted a final rule implementing the Volcker Rule. The text of the final rule and its accompanying preamble are available here. The Volcker Rule was created...more