Seth Eaton Discusses Modifications and Workouts of Commercial Real Estate Loans during the COVID-19 Pandemic
The SEC released the final Securities Act Rule 192 relating to conflicts of interest in asset-backed securities transactions on November 27, 2023. In this OnPoint, we summarize the provisions of the final Rule 192 and...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
On May 20, 2020, the Federal Reserve Bank of New York (the "New York Fed") released the form of Master Loan and Security Agreement ("MLSA") that will govern loans issued under its Term Asset-Backed Loan Facility ("TALF") and...more
The US Treasury Department and the Federal Reserve Bank of New York (the New York Fed) have announced the complete terms of a new Term Asset-Backed Securities Loan Facility (TALF) program, which is intended to address the...more
On Wednesday, May 20, 2020, the Federal Reserve announced the first loan subscription date for the Term Asset-Backed Securities Loan Facility (“TALF”) and published the Master Loan and Security Agreement (the “MLSA”) and an...more
In response to the economic consequences of the measures being taken to contain the spread of the novel coronavirus (COVID-19), the Board of Governors of the Federal Reserve System (the "Federal Reserve") revived the Term...more
On May 12, 2020, the Federal Reserve Bank of New York (the “New York Fed”) announced the issuance of updated Terms and Conditions1 and a Frequently Asked Questions document (the “FAQs”)2 regarding the 2020 Term Asset-Backed...more
The US Treasury Department and Federal Reserve Bank of New York recently released a new set of FAQs and a revised term sheet for the new Term Asset-Backed Securities Loan Facility (TALF) program, which is intended to address...more
On May 12, 2020, the Federal Reserve published an updated Term Sheet and a set of Frequently Asked Questions (“FAQs”) for the Term Asset-Backed Securities Loan Facility ("TALF"). The TALF program, which was first announced on...more
As part of a number of liquidity measures announced in response to the COVID-19 pandemic, the Federal Reserve re-established the Term Asset-Backed Securities Loan Facility (“TALF”) on March 23, 2020....more
On May 12, 2020, the Board of Governors of Federal Reserve System (the “Fed”) published a revised term sheet for the Term-Asset Backed Securities Loan Facility (the “TALF”)...more
On April 9, 2020, the Federal Reserve released an updated term sheet for the Term Asset-Backed Securities Loan Facility ("TALF"). The TALF program, which was first announced on March 23, 2020, will provide a funding backstop...more
On April 9, 2020, the Federal Reserve Board of Governors (the “Fed”) released an updated term sheet (the “Updated Term Sheet”) for the Term Asset-Backed Securities Loan Facility (“TALF”) program. While the Updated Term Sheet...more
The US Treasury Department and Federal Reserve Bank of New York last week announced changes to the new Term Asset-Backed Securities Loan Facility (TALF) program, which is intended to address the liquidity crisis caused by the...more
On March 23 the Federal Reserve announced the creation of the Term Asset-Backed Securities Loan Facility, or TALF to support the asset-backed securities (ABS) market. The new facility (commonly referred to in the market as...more
Last week, the Federal Reserve announced additional actions to support the U.S. economy, which included expanding its Term Asset-Backed Securities Loan Facility (“TALF 2020”) to include legacy commercial mortgage-backed...more
On April 9, 2020, the Federal Reserve Bank of New York (the Federal Reserve) announced updates to the 2020 Term Asset-Backed Securities Loan Facility (TALF). The updates include expanding the eligible underlying asset classes...more
In response to the current credit crisis triggered by the COVID-19 pandemic, on March 23, the Federal Reserve Bank of New York (the Federal Reserve) revived the Term Asset-Backed Securities Loan Facility (TALF) first...more
TALF Extended to Legacy CMBS and CLOs - On April 9, 2020, the Federal Reserve unveiled an array of additional programs to bolster the U.S. economy in response to the COVID-19 pandemic. One of those programs is aimed at...more
Phones are ringing; borrowers are panicked and so are their lenders. Borrowers who were profitable, good customers three or four weeks ago are suddenly struggling in the wake of the coronavirus crisis. They are seeking...more
Under the recently announced Term Asset-Backed Securities Loan Facility (the “2020 TALF”), the New York Federal Reserve will commit to lend on a recourse basis to a special purpose vehicle (the “TALF SPV”), which will...more
Earlier this week, we noted that COVID-19 might be the pin that bursts a corporate debt bubble. Unfortunately, corporate debt is not the only type of debt poised to explode, particularly under mounting pressure from COVID-19...more
Second Circuit Raises Bar for US Jurisdiction Over Foreign Banks - Orrick litigators Robert Reznick, Stephen Foresta and Julie Gorchkova co-authored an article for Law360 that examines a closely-watched case relating to...more
On October 22, 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, the Federal Housing...more
Credit risk retention rules are intended to promote an alignment of interests between sponsors and investors of securitizations by requiring sponsors to maintain “skin in the game” — that is, retain a certain percentage of...more