It’s here at last—well, the next set of steps towards a brave new dawn for consumer credit, at least. No sooner have we taken down the bunting and put the final champagne glasses in the dishwasher, having celebrated the 40th...more
Following the recent Russian invasion of Ukraine, many countries, including the United States, the United Kingdom and member states of the European Union, have imposed a coordinated series of sanctions unprecedented in scope...more
On 21 October 2021, the UK Treasury (Treasury) published a consultation paper setting out policy options for the regulation of “buy now, pay later” (BNPL) credit agreements. The consultation follows the publication of...more
HMT has today published its much-anticipated consultation on regulating the Buy-Now-Pay-Later (BNPL) credit market, following the Woolard Review recommendation that all BNPL products are brought within the regulatory...more
On 2 February 2021, the Financial Conduct Authority (the FCA) published a report on the U.K. unsecured credit market (the Woolard Report), which makes several recommendations designed to generate alternatives to high-cost...more
The Woolard Review emphasises the urgency to bring all BNPL products under FCA supervision and sets out recommendations for the unsecured credit market. The UK government has announced that interest-free buy-now-pay-later...more
This bulletin provides a timely update on two emerging issues related to LIBOR transition – namely, requirements that administrative agents (including private credit lenders acting in that role on their facilities) may be...more
As most market participants are aware, in 2017, the Financial Conduct Authority (FCA), a financial regulatory body in the UK, announced that LIBOR would be phased out. The announcement was made, in part, in recognition of the...more
The Situation: The Alternative Reference Rates Committee ("ARRC") released market consultations on the securitization and bilateral loan markets on December 7, 2018, concerning potential paths forward for benchmark (e.g.,...more
U.S. Financial Industry Developments - FINRA Requests Comment on Financial Technology Innovation in the Broker-Dealer Industry - On July 30, 2018, the Financial Industry Regulatory Authority ("FINRA") published a...more