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New SEC Staff Guidance Broadens the Applicability of 1940 Act Exemption for Mortgage Securitizers

In a no-action letter dated February 12, 2018, the SEC expanded the scope of Section 3(c)(5)(C) of the Investment Company Act to apply to a sponsor of multiple securities trusts that hold whole mortgage loans....more

Treasury Issues Report and Recommendations on Capital Markets

On October 6, 2017, the US Department of the Treasury released a 220-page report on reforming the US regulatory system for the capital markets (Capital Markets Report). The Capital Markets Report includes 91 recommendations...more

SEC Moves Closer to Registration of Security-Based Swap Dealers and Major Security-Based Swap Participants

On August 5, 2015, the US Securities and Exchange Commission (“SEC”) took several incremental steps toward completing its regulatory framework for security-based swap dealers and majority security-based swap participants...more

Credit Risk Retention Rules Finalized

Six federal agencies have finalized long-anticipated joint rules imposing risk retention, or “skin-in-the-game,” requirements for securitizations. The new rules, when they become effective over the next two years, will impose...more

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