The time is nigh. The COVID-19 pandemic makes a significant economic downturn in 2020 more probable than ever. More than a decade after the start of the Great Recession, we stand at the precipice of another recession. It was...more
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
On February 9, 2018, the D.C. Court of Appeals ruled that treating managers of open-market CLOs as “securitizers” subject to the risk retention rules exceeded the statutory authority to promulgate rules to implement the risk...more