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Final Rules Collateralized Loan Obligations

Dechert LLP

EU Securitisation Regulation - European Commission Publishes Final Disclosure Templates Expected to Apply from February 2020

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No Good News, but No Bad News Either - On 16 October 2019 the European Commission (EC) adopted a delegated regulation supplementing Regulation (EU) 2017/2402 (the Securitisation Regulation) and setting out the final...more

K&L Gates LLP

New Japanese Securitization Risk Retention Rule and Its Impact on CLO Investors in Japan

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In December 2018, the Financial Services Agency of Japan (the “JFSA”) proposed amendments to its regulations under the Banking Act of Japan to introduce a new risk retention rule applicable to collateralized loan obligations...more

Dechert LLP

Japanese Risk Retention: JFSA Favors Diligence Over Disruption

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The new Japanese Risk Retention Rules will lead to increased loan and collateral manager due diligence by Japanese investors but not wholesale changes to the CLO market. Background - On March 15, 2019, the Japanese...more

Dechert LLP

Japanese Risk Retention: Tidal Wave or Ripple in Still Waters?

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On December 28, 2018, the Japanese Financial Services Agency (the “JFSA”) published a number of notices detailing proposed changes in the regulatory capital requirements applicable to Japanese banks and certain other...more

Dechert LLP

DC Circuit Court Newsflash: “Transfer” means “Transfer”

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In an eagerly anticipated (and much speculated upon) decision, a three judge panel of the United States Court of Appeals for the District of Columbia Circuit (“DC Circuit Court”) issued a unanimous opinion on Friday, February...more

Dechert LLP

U.S. Risk Retention Final Rule: Capitalized Manager Vehicles, Majority Owned Affiliates and Other FAQs

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Since its initial release we have received numerous inquiries from market participants (clients and non-clients alike) concerning the meaning and ramifications of the final U.S. risk retention rule (the “Final Rule”) on...more

Dechert LLP

Coal in Your CLO Stocking: U.S. Risk Retention Effective Date

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The federal regulatory agencies responsible for implementing regulations under The Dodd-Frank Wall Street Reform and Consumer Protection Act finalized rules for risk retention requirements in CLO transactions (the “Final...more

Dechert LLP

Credit Risk Retention Final Rule: Enforcement and Compliance Considerations

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Predicting enforcement of the final rule regarding U.S. risk retention is an uncertain task. This OnPoint is designed to provide guidance on possibilities related to consequences of non-compliance, enforcement approaches by...more

Blank Rome LLP

U.S. Regulatory Update–Final Rules: Credit Risk Retention for CLOs

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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

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