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CFTC Seeks Public Comment on Proposed Whistleblower Rule Amendments

On September 1, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) announced that it is “requesting public comment on proposed amendments to the Whistleblower Rules found in Part 165 of the CFTC’s regulations.” The...more

CFTC Signs Memorandum of Understanding with Two Mexican Authorities to Enhance Supervision of Cross-Border Regulated Entities

On September 6, 2016, the U.S. Commodity Futures Trading Commission announced that it “signed a Memorandum of Understanding (MOU) with the Comisión Nacional Bancaria y de Valores (CNBV) and the Banco de México (BDM) regarding...more

Rating Agency Developments

On September 7, 2016, Moody’s updated and replaced its approach to assessing credit risk for U.S. charter schools. Report. On September 7, 2016, S&P published its global framework criteria for rating securitizations of...more

9/13/2016  /  DBRS , Fitch , Moody's , Rating Agencies , RMBS

Rating Agency Developments

On August 16, Moody’s supplemented its approach to rating residential mortgage-backed securities (RMBS) in China. Report. On August 16, Fitch updated its country ceilings cross-sector criteria report. Report....more

8/19/2016  /  Fitch , Moody's , Rating Agencies , RMBS

Rating Agency Developments

On July 19, 2016, DBRS published its criteria for rating CLOs backed by loans to European SMEs (small and medium-sized enterprises).  Report. On July 18, 2016, Fitch published its criteria for assigning new and existing...more

7/25/2016  /  CMBS , Covered Bonds , DBRS , EU , Fitch , Structured Finance

Interim Final Rule Regarding Inflation-Adjusted Civil Money Penalties

On July 1, 2016, the Office of the Comptroller of the Currency (OCC) published an interim final rule that amends its rules of practice for national banks and federal savings associations to adjust the maximum amount of each...more

Rating Agency Developments

On July 6, 2016, Moody’s published its rating methodology for European Social Housing Providers. Report. On July 5, 2016, Fitch updated its global surveillance criteria for structured finance CDOs. Report....more

Rating Agency Developments

On June 29, 2016, Moody’s published its rating methodology for trading companies. Report. On June 29, 2016, DBRS published its rating methodology for Canadian structured income funds. Report. On June 29, 2016, DBRS published...more

7/8/2016  /  DBRS , Moody's , Rating Agencies

SEC Adopts Rule on Disclosure of Payments by Resource Extraction Issuers

On June 27, 2016, the Securities and Exchange Commission announced that it adopted rules, mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act, to require resource extraction issuers to disclose payments...more

SEC Adopts Amendment to Form 10-K

On June 1, 2016, the Securities and Exchange Commission (SEC) approved an interim final rule implementing Section 72001 of the Fixing America’s Surface Transportation (FAST) Act. The rule allows Form 10-K registrants to...more

Rating Agency Developments

On May 27, 2016, S&P published its revised rating criteria for hedge fund securitizations.  Report. On May 26, 2016, Fitch published its revised sovereign rating criteria.  Report. On May 26, 2016, DBRS published its...more

FHFA Increases 2016 Multifamily Lending Caps

On May 4, 2016, the Federal Housing Finance Agency announced that it increased its 2016 multifamily lending caps for Fannie Mae and Freddie Mac from $31 billion to $35 billion.  The increase is based on growing estimates of...more

Agencies Propose Net Stable Funding Ratio Rule

On May 3, 2016, the Federal Deposit Insurance Corporation, the Federal Reserve and the Office of the Comptroller of the Currency proposed a rule, the net stable funding ratio (the “NSFR”), to strengthen banks by requiring...more

Rating Agency Developments

On May 3, 2016, DBRS published its rating methodology for pooled aircraft lease securitizations. Report. On May 3, 2016, DBRS published its master U.S. ABS surveillance methodology. Report. On May 3, 2016, S&P published its...more

CFTC Amends Swap Portfolio Reconciliation Requirement

On May 2, 2016, the U.S. Commodity Futures Trading Commission approved a final rule to amend the swap portfolio reconciliation requirement. Under CFTC Regulation 23.500(i), swap dealers and major swap participants were...more

No-Action Relief Regarding Masking Information Reportable under the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the masking of information reportable under the ownership and control final rule (the “OCR...more

4/22/2016  /  CFTC , Final Rules , No-Action Relief , OCR

Rating Agency Developments

On April 13, Moody’s published its approach to rating obligations with variable promises, where the source of variation is related to non-standard or non-credit-related reference factors. ...more

No-Action Letter Issued Regarding the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the ownership and control final rule (the “OCR Final Rule”). The OCR Final Rule requires...more

The FDIC Rescinds De Novo Time Period Extension

On April 6, 2016, the Federal Deposit Insurance Corporation (the “FDIC”) rescinded Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions. ...more

The Federal Reserve Board Finalizes Rule Regarding Investment-Grade General Obligation State and Municipal Securities

On April 1, 2016, the Federal Reserve Board finalized a rule to include certain U.S. general obligation state and municipal securities in the type of assets that financial institutions may use to satisfy requirements designed...more

Rating Agency Developments

On April 6, 2016, DBRS published its methodology for rating European structured finance transactions. On April 6, 2016, DBRS published its methodology for ratings in the forest products industry. On April 6, 2016, DBRS...more

4/12/2016  /  DBRS , EU , Fitch , Rating Agencies , S&P

Rating Agency Developments

On March 2, S&P updated its criteria for rating certain U.S. RMBS backed by pre-2009 originated mortgage loans. On March 1, Moody’s updated its rating methodology for U.S. public electric utilities with generation ownership...more

Rating Agency Developments

On February 2, DBRS released its critical obligations rating criteria. On February 1, KBRA released its general rating methodology as it pertains to corporate issuers....more

FHFA, Fannie Mae and Freddie Mac Announce Independent Dispute Resolution Program

On February 2, the Federal Housing Finance Agency (the “FHFA”) announced that Fannie Mae and Freddie Mac have implemented an independent dispute resolution process for resolving repurchase disputes. The process would allow...more

Rating Agency Developments

On January 6, DBRS published its methodology for rating European commercial mortgage loans and European CMBS transactions. On January 4, DBRS published its preferred share and hybrid security criteria for corporate issuers....more

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