News & Analysis as of

Disclosure Requirements Rating Agencies

Dechert LLP

International Capital Markets - October 2022, Issue 7: Issuer considerations during difficult market conditions

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As we approach the end of 2022, the international debt capital markets continue to remain challenging due to the successive shocks of the COVID-19 pandemic and ongoing supply chain disruptions, the war in Ukraine and...more

Dechert LLP

Collateralized Fund Obligations (CFOs): The Technicolor Dreamcoat of Fund Finance

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Over the past several years as Collateralized Loan Obligations (“CLOs”) reached new and dizzying heights in issuance volume, CFOs have been quietly, and under the radar, gaining market acceptance and momentum among asset...more

Mintz

Rating Agencies Focus on ESG Concerns

Mintz on

Last week, Fitch Ratings announced the launch of new ESG ratings system, which is intended to use a "clear methodolog[y]," of a "full assessment of ESG performance" that "allow[s] for detailed comparability." This...more

King & Spalding

SEC Brings Action Against Morningstar Alleging Undisclosed CMBS Rating Adjustments

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On February 16, 2021, the SEC filed a litigated civil complaint in the Southern District of New York against Morningstar Credit Ratings LLC, a former Nationally Recognized Statistical Rating Organization (“NRSRO”) alleging...more

Troutman Pepper

SEC's Leveraged Loan Market Outlook

Troutman Pepper on

On September 19, the Securities and Exchange Commission’s Investor Advisory Committee held a hearing to discuss the risks of increased leverage in the loan market and the potential impact leveraged loans and collateralized...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

U.S. Financial Industry Developments - SEC Disapproves the Listing and Trading of Nine Bitcoin Related Exchange Traded Products - On August 22, 2018, the SEC released three Orders, acting through authority delegated to...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

SEC Proposes Rules to Implement FAST Act Mandate to Modernize and Simplify Disclosure - On October 11, 2017, the Securities and Exchange Commission (SEC) proposed amendments "to modernize and simplify disclosure...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Agencies to Propose Amending CRA Regulations to Conform to HMDA Regulation Changes, and Remove References to the Neighborhood Stabilization Program - On September 13, 2017, the Board of Governors of the Federal Reserve...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - SEC Publishes Compliance and Disclosure Guidance for Regulation Crowdfunding - On April 5, 2017, the Division of Corporation Finance of the Securities and Exchange Commission...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

FHFA Issues Final Rule on Fannie Mae and Freddie Mac Duty to Serve Underserved Markets - On December 13, 2016, the Federal Housing Finance Agency (FHFA) issued a final rule implementing the Duty to Serve provisions...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more

Holland & Knight LLP

Jury Finds Miami and Former Budget Director Guilty of Securities Fraud

Holland & Knight LLP on

In the first federal jury trial by the U.S. Securities and Exchange Commission (SEC) against a municipality or its officers, jurors found that the City of Miami, Florida (Miami or the City) and its former budget director...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

SEC Approves IEX Proposal to Launch National Exchange, Issues Interpretation on Automated Securities Prices - On June 17, 2016, the Securities and Exchange Commission ("SEC") approved the application of Investors'...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

SEC Updates Compliance and Disclosure Interpretations for Legacy Deals - On September 16, the SEC released its updated compliance and disclosure interpretations for the rules adopted under Regulation AB, the Securities...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

EBA Outlines Upcoming Initiatives for the Regulation of Retail Payments - The European Banking Authority ("EBA") has announced details of its plans to harmonize regulatory and supervisory practices to ensure secure, easy...more

Kelley Drye & Warren LLP

Corporate Governance Update – January 2015

1) SEC Grants Second Bad Actor Waiver with Conditions - On January 27th, the Securites and Exchange Commission granted Oppenheimer a bad actor waiver under Rule 506(d). ...more

Cadwalader, Wickersham & Taft LLP

At Long Last—SEC Adopts Final Regulation AB II

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

Dechert LLP

Final REG AB Rules: Man Bites Dog

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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

Goodwin

SEC Adopts Final Credit Rating Agency Rules

Goodwin on

The SEC adopted new rules and rule amendments (collectively, the “Final Rules”) that impose a range of additional requirements on credit rating agencies registered as nationally recognized statistical rating organizations...more

Dechert LLP

New Regulation AB II and NRSRO Rules Released

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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

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review - April 14, 2014

Agencies Apply Increased Leverage Ratio to Large U.S. Banks - On April 8, the Fed, FDIC and OCC adopted the final rule to increase the leverage ratio for the largest U.S. banks. The final rule applies to U.S. bank...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review - August 19, 2013

CFPB Update on Mortgage Regulation Exam Procedures - On August 15, the CFPB released a second update to its exam procedures in connection with mortgage regulations to cover: (i) ability-to-repay; (ii) qualified...more

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