Corporate CLO issuers, regardless of whether they are organized onshore or offshore, should generally be exempt from Corporate Transparency Act reporting requirements, although onshore CLO co-issuers will likely be subject to...more
Senators Introduce SAFE Lending Act - On April 7, 2016, several Democratic Senators introduced the Stopping Abuse and Fraud in Electronic (SAFE) Lending Act, SAFE 2016, which is designed to change the manner in which...more
The FCPA in 2016: DOJ and SEC Focus on International Cooperation and Investigation of Individuals - Why it matters: As we reported in our December 2015 newsletter, both SEC Enforcement Director Andrew Ceresney and DOJ...more
ESCB Reports on the Access of CCPs to Central Bank Liquidity Facilities under EMIR - On August 25, 2015, the European Central Bank (ECB) published a report by the European System of Central Banks (ESCB) on the need for...more
CFTC Announces New Approach for Considering Requests for Relief from Registration for Delegating Commodity Pool Operators - On May 12, CFTC Division of Swap Dealer and Intermediary Oversight announced a streamlined...more
In This Issue: CFPB Final Rule Amendments to Ability to Repay and QM Rule; Extension of Loan Modification Programs; Freddie Mac $1 Billion Performing Modified Loan Securitization; FinCEN Guidance on Virtual Currency...more