Consumer Finance Monitor Podcast Episode: Did the Supreme Court Hand the CFPB a Pyrrhic Victory?
Consumer Finance Monitor Podcast Episode: Understanding the Federal Reserve Board Proposal to Lower Interchange Fee Cap for Debit Card Transactions
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
The Future of Payments: Exploring FedNow With the Payments Professor — Payments Pros – The Payments Law Podcast
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: What is FedNow and its Role in the U.S. Payments System?
Breaking (Down) the Debt Ceiling
Podcast: 2023 Deal Cycle - Considerations for Transactions in Uncertain Economic Times - Diagnosing Health Care
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Is the U.S. Payments System Failing Business and Consumers? A Discussion with Special Guest Dan Awrey, Professor of Law, Cornell Law School
DE Under 3: Latest Monthly Jobs Report, Unemployment & the US BLS JOLTS Report
Stablecoin Regulation in an Unstable Time: The Fed and Treasury Address a Stablecoin Regulatory Framework
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
The Return of TALF Fund Opportunities Via COVID-19 Relief
Regulators Tackle Board Effectiveness and Overdrafts
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
This is just a short note, with little actual utility, but it’s about something that’s really bothering me. Why are we so calm? What has anesthetized us?...more
Several weeks ago, I wrote a commentary called Funny Times in which I bemoaned the complete lack of coherent data, making the process of predicting the course of interest rates, cap rates and transactional velocity over the...more
CRE CLO technology is languishing in the toolbox. A combination of high interest rates, a mispriced legacy book, an anxious investor base and no real need to refresh capital until borrowers start borrowing again is largely...more
Our fine little CRE CLO business has exploded over the past couple of years, hasn’t it? Last year, around this time, I recklessly predicted for my friends at Commercial Mortgage Alert that we might hit $30 billion of...more
Here at Dechert, we have market-leading practices in CRE CLO as well as corporate CLOs, including broadly syndicated and middle market structures. So, every day that I peer into these two alternate universes, I’m astonished...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
The form of agreed-upon procedures report provides additional clarity regarding certain TALF-required CLO report requirements. On September 1, 2020, the Federal Reserve released a form of agreed-upon procedures report...more
Introduction - As the reinstated Term Asset-Backed Securities Loan Facility program (“TALF 2.0”) opened, the Federal Reserve Bank of New York (the “FRBNY”) continues to revise the TALF 2.0 program details, changing the...more
The Fed throws a bone to the CLO market by reducing the non-call period from three years to one year, but this small victory will likely have little impact given the numerous obstacles which remain unaddressed....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
As of May 28, 2020 - 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...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
As revised, TALF may provide a safety net in the event of catastrophic CLO market conditions but is not likely to meet the goal of reviving the corporate loan market Introduction - On May 12, 2020, the Federal Reserve...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
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
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
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