ISDA, FIA and the Institute of International Finance responded to issues concerning central counterparty ("CCPs") resolution raised in a discussion paper published by the Financial Stability Board ("FSB"). The comment letter addresses CCP equity, the amount of "skin in the game" a CCP should be required to maintain (that is, the amount of losses it must absorb before imposing losses on clearing members), and the rules that should govern "No Creditor Worse Off than in Liquidation" claims in the event that a CCP is resolved rather than being liquidated.

The FDIC and the Federal Reserve Board advised financial institutions on the provisions for "Voluntary Loan Rehabilitation Programs" under Section 602 of the Economic, Growth, Regulatory Relief and Consumer Protection Act. Among other highlights, financial institutions can offer a loan rehabilitation program ( i.e., a Section 602 Program) to qualifying borrowers who have "reported default" on a private education loan. Under a Section 602 Program, a financial institution can "remove a reported default from the borrower's credit report" without being deemed "inaccurate" under the Fair Credit

In an updated Investor Bulletin, the SEC Office of Investor Education and Advocacy ("OIEA") explained what it means to be an accredited investor. The OIEA also provided information on how to calculate net worth for purposes of determining whether a person qualifies as an accredited investor, and clarified that the value of an investor's primary residence is not included in the net worth calculation.

On January 31, 2019, European Securities and Markets Authority ("ESMA") revised its draft disclosure technical standards and issued supporting draft Q&As under the EU Securitization Regulation.

Federal Reserve Board ("FRB") Governor Lael Brainard summarized comment letters submitted by academics, banks, banking trade associations, community and consumer groups, related to the Office of the Comptroller of the Currency's proposed rulemaking to reform the Community Reinvestment Act ("CRA"). In remarks before the "Research Symposium on the Community Reinvestment Act," sponsored by the Federal Reserve Bank of Philadelphia, Ms. Brainard noted that commenters, community and consumer groups: applauded the volume of CRA loans and investments that support low-and-moderate income households and