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International Organization of Securities Commissions February 20, 2012 The Technical Committee of the International Organisation of Securities Commissions (IOSCO) has published a consultation report on the Principles for Ongoing Disclosure for Asset Backed Securities. The report contains principles designed to provide guidance to securities regulators who are developing or reviewing their regulatory regimes for ongoing disclosure for asset backed securities. The closing date for responses is Friday April 20, 2012. Cross References: Press Release

Six federal agencies - including the Board of Governors of the Federal Reserve System, Department of Housing and Urban Development, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Office of the Comptroller of the Currency, and the SEC - issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule which the agencies issued in 2011 to implement the risk retention requirement in Dodd-Frank. Linked below is a description of the re-proposal prepared by the Structured

Three federal financial institution regulatory agencies including the Board of Governors of the Federal Reserve System ("FRB"), the Office of the Comptroller of the Currency ("OCC"), and the Federal Deposit Insurance Company ("FDIC") provided clarification and guidance to banking entities regarding investments in "Covered Funds" (as defined in the Volcker Rule), and how collateralized debt obligations backed by trust preferred securities ("TruPS CDOs") should be treated under the Volcker Rule. The FAQ addresses the following principal questions: (i) whether a TruPS CDO is a Covered Fund, (ii)

The Loan Syndications and Trading Association, SIFMA, the Structured Finance Industry Group, the American Bankers Association, and the Financial Services Roundtable (together, the "Trade Associations") sent a letter to federal regulators requesting that they clarify how certain provisions of the recently issued "Volcker Rule" regulations would apply to debt securities of collateralized loan obligation ("CLO") issuers. In particular, with respect to CLO issuers that are considered "covered funds," the Trade Associations requested that the regulators clarify that holding debt securities issued

The SEC, the Board of Governors of the Federal Reserve System ("FRB"), the FDIC, and the Office of the Comptroller of the Currency ("OCC") (the "Agencies") stated that they are reviewing whether it would be appropriate, and consistent with Dodd-Frank, not to subject collateralized debt obligations backed by trust preferred securities to the investment prohibitions of Dodd-Frank Section 619, or the Volcker Rule. According to the SEC release, a number of community banking organizations have expressed concern that the final Volcker Rule conflicts with the Congressional determination under Dodd