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NRSRO

Cadwalader, Wickersham & Taft LLP

February 2024 Regulatory Round-Up

As February already begins to wind down and all of us are wondering what we might have missed so far this year, here is a round-up of additional regulatory activities in financial services...more

Dechert LLP

The NAIC Goes Into Selective Override

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The National Association of Insurance Commissioners (“NAIC”) recently concluded its summer meeting, which took place from August 12 to 16, 2023. The Valuation of Securities (E) Task Force (the “VOS Task Force”) and other...more

Ballard Spahr LLP

SEC Nears First Settlement With a Credit Rating Agency in Off-Channel Communications Sweep

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Summary - The Securities and Exchange Commission (SEC) is reportedly nearing a settlement with a nationally recognized statistical rating organization (NRSRO) over its failure to preserve certain credit-ratings...more

Dechert LLP

Crisis Averted (Part IV)? Close Calls and Lessons for CRE Lenders After Recent Bank Shutdowns.

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In our prior three articles, we discussed the potential impact of the recent bank shutdowns on cash management arrangements and guarantor financial covenants in commercial real estate lending. The issues we identified could...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: July 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

Akin Gump Strauss Hauer & Feld LLP

The New Burden of Proof for Private Ratings

In this issue of Make (Whole) A Minute, we examine the new ratings rationale reporting requirements being implemented by the NAIC’s Securities Valuation Office. Insurance regulators have long sought greater transparency into...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

Vinson & Elkins LLP

Current And Predecessor Lessees And Grant Holders Take Heed: BSEE And BOEM Propose Revisions In Offshore Decommissioning...

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On October 16, 2020, the Bureau of Safety and Environmental Enforcement (“BSEE”) and the Bureau of Ocean Energy Management (“BOEM”), both agencies of the U.S. Department of the Interior, published a joint notice of proposed...more

Morgan Lewis

Updated Guide to the 2020 Term Asset-backed Securities Loan Facility (TALF) Program (UPDATED)

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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

Orrick, Herrington & Sutcliffe LLP

“TALF 2.0”: A Primer for TALF-eligible Asset-backed Security Issuers

In March 2020, the Federal Reserve (the “Fed”) announced that it would re-establish the Term Asset-Backed Securities Loan Facility (“TALF”) program, a market stabilization tool that was developed and last used by the Fed...more

Dechert LLP

FRBNY Further Revises TALF 2.0 FAQs; SEC Issues No-Action Relief for Registered Fund and BDC Participants

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Introduction - As market participants prepare for the launch of the latest version of the Term Asset-Backed Securities Loan Facility (“TALF”) program (“TALF 2.0”), two new developments provide greater clarity as to how the...more

Morgan Lewis

Guide To The 2020 Term Asset-backed Securities Loan Facility (TALF) Program

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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

Mayer Brown

TALF 2020 Update: MLSA, Revised FAQs and Related Program Materials

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On May 20, 2020, the Federal Reserve Bank of New York (“FRBNY” or the “Fed”) announced the first subscription date, June 17, 2020, in connection with the Term Asset-Backed Securities Loan Facility (“TALF 2020”). The Fed also...more

Cadwalader, Wickersham & Taft LLP

COVID-19 Update: Updated FAQs and MLSA Released by the Federal Reserve Provides Additional Details on Eligible ABS, Eligible...

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

Mayer Brown

Federal Reserve Releases TALF FAQs: Here are the Highlights

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On May 12, 2020, the Federal Reserve (Fed) published updates to the term sheet for the Term Asset-Backed Securities Loan Facility (the TALF), and FAQs regarding the TALF, including additional details regarding borrower and...more

Dechert LLP

Federal Reserve Releases FAQ for the Primary Market Corporate Credit Facility (PMCCF)

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On May 4, 2020, the Federal Reserve Bank of New York (the “Federal Reserve”) released Frequently Asked Questions (the “FAQs”) regarding the Primary Market Corporate Credit Facility (“PMCCF”) program, providing greater detail...more

Morrison & Foerster LLP

Federal Reserve Updates Key Features Of The Municipal Liquidity Facility

On April 27, 2020, the Board of Governors of the Federal Reserve System (“FRB”) amended the term sheet for its Municipal Liquidity Facility (“MLF”) to expand the scope and duration of the facility (the “April 27 Update”). ...more

Locke Lord LLP

Help for State and Local Governments: Federal Reserve Issues Additional Guidance on Municipal Liquidity Facility

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On Monday, April 27th, the Federal Reserve announced additional guidance regarding its Municipal Liquidity Facility (the “Facility”), which was first announced on April 9th and was established to buy short-term debt in...more

Cadwalader, Wickersham & Taft LLP

COVID-19 Update: Extraordinary Measures in Extraordinary Times: The Federal Reserve Responds to the Coronavirus Pandemic

The Federal Reserve has established a number of programs to provide targeted support to the corporate credit, asset-backed securities, money market and commercial paper markets in light of the evolving coronavirus disease...more

Ballard Spahr LLP

Federal Reserve Provides $2.3 Trillion in Loans

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On April 9, 2020, the Federal Reserve issued a press release announcing that it would be seeking to undertake additional actions to provide up to $2.3 trillion in loans to support the economy. ...more

Orrick - Finance 20/20

SEC Publishes Two Reports on Credit Rating Agencies Showing Continued Focus on Compliance and Competition

On December 18, the Securities and Exchange Commission (“SEC”) published a report on the recognized statistical rating organizations and another report about such organizations’ examinations....more

Robins Kaplan LLP

Your Daily Dose of Financial News

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Local-TV powerhouse Sinclair Broadcast Group isn’t all that well known outside of the Baltimore area, but it’s making a big play for the national stage as it nears a deal to buy Tribune Media—the former “Tribune empire’s...more

Ballard Spahr LLP

Investment Management Update - April 2016

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. ...more

Dechert LLP

SEC Amends Rule 2a-7 to Eliminate References to NRSRO Ratings and to Revise Issuer Diversification Requirements

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The U.S. Securities and Exchange Commission (SEC) recently adopted amendments (Amendments) to remove references to credit ratings in Rule 2a-7 under the Investment Company Act of 1940, as amended (1940 Act), the primary rule...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

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