News & Analysis as of

Federal Reserve Collateralized Loan Obligations Volcker Rule

Jones Day

Volcker Rule Covered Fund Amendments Provide Clarity and Opportunities

Jones Day on

The Situation: The Federal Reserve, Office of the Comptroller of the Currency ("OCC"), Federal Deposit Insurance Corporation ("FDIC"), Securities and Exchange Commission ("SEC"), and Commodity Futures Trading Commission...more

Orrick, Herrington & Sutcliffe LLP

Rolling Back the Impact of the Volcker Rule on CLOs

Last week 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 and the Commodity Futures...more

Burr & Forman

Dodd-Frank News: May 2014: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

Burr & Forman on

In This Issue: - RECENT CASES ..Preemption ..CFPB Involvement in Litigation ..CFTC Regulation of Retail Commodity Transactions ..Durbin Amendment ..Appraiser Disclosure Requirements Under...more

Dechert LLP

Fed Issues Additional Guidance on Extended Conformance Period – Be Careful What You Ask For

Dechert LLP on

A few steps forward and a giant leap back. This familiar phrase might be the perfect summary of the CLO market’s Volcker Rule roller coaster since December 2013. A few weeks ago we wrote about the Federal Reserve Board’s...more

Ballard Spahr LLP

Federal Reserve Extends Compliance Period under Volcker Rule for Collateralized Loan Obligations

Ballard Spahr LLP on

While collateralized loan obligation vehicles (CLOs) may ultimately have to be divested by “banking entities” subject to the Volcker Rule, the Federal Reserve Board (the Board) recently extended the compliance period for...more

Katten Muchin Rosenman LLP

Federal Reserve Extends Compliance Deadline for CLOs

On April 7, the Federal Reserve Board (Board) announced that it intends to exercise its authority to give banking entities two additional one-year extensions to conform their ownership interests in, and sponsorship of,...more

Dechert LLP

Federal Reserve Extends Volcker CLO Compliance Period

Dechert LLP on

On April 7th the Federal Reserve Board (the “Fed”) announced that it would provide banking entities with two additional one-year extensions to conform their ownership of CLOs covered by the Volcker Rule. The Fed stated that...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Final Volcker Rule: Impact on Securitizations

On December 10, 2013, five U.S. financial regulators (the Agencies) adopted a final rule implementing the Volcker Rule (the Final Rule). The text of the Final Rule and its accompanying lengthy preamble (collectively, the...more

Dechert LLP

CLOs Under the Volcker Rule: New Exemptions, New Issues, New Obligations

Dechert LLP on

Under the final version of the Volcker Rule issued this week, issuers and sponsors of new CLO issuances should consider structuring CLOs to conform to the exclusions contained in the rule, and banks and bank affiliates that...more

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