Alex Radisich, an associate in Orrick's Los Angeles office, is a member of the firm's Structured Finance and Banking and Finance Groups. 

During law school, Alex served as a judicial extern to the Honorable Judge Harry Pregerson of the United States Court of Appeals for the Ninth Circuit, and as a law clerk on the Senate Judiciary Committee for Senator Dianne Feinstein.

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Posts by: Alexander Radisich

OCC Provides Additional Details to Evaluate Charter Applications From fintech Companies

 

On March 15, 2017, the Office of the Comptroller of the Currency (“OCC“) issued a “Draft Licensing Manual Supplement for Evaluating Charter Applications from Financial Technology Companies,” which provides additional details on the evaluation of national bank charter applications from financial technology (“fintech“) companies that engage in the business of banking. The supplement explains how the OCC will apply the licensing standards and requirements in existing regulations and policies to fintech companies applying for special purpose national bank charters. The supplement also describes unique factors that the agency will consider in evaluating applications from fintech companies; expectations for promoting fair access, fair treatment and financial inclusion; and the agency’s approach to supervising those fintech companies that become national banks. Release. Manual Supplement.

Nationstar Mortgage to Pay $1.75 Million Penalty for HMDA Violations

 

On March 15, 2017, the Consumer Financial Protection Bureau (“CFPB“) ordered Nationstar Mortgage LLC (“Nationstar“) to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (“HMDA“) by consistently failing to accurately report data about mortgage transactions between 2012 through 2014. The $1.75 million civil penalty is the largest HMDA penalty imposed by the CFPB to date. The CFPB found that (1) Nationstar’s HMDA compliance systems were flawed and generated mortgage lending data with significant, preventable errors; (2) Nationstar failed to maintain detailed HMDA data collection and validation procedures and failed to implement adequate compliance procedures; and (3) Nationstar failed to consistently define data among its various lines of business. In addition to the civil penalty, the CFPB ordered Nationstar to develop and implement an effective compliance management system and to review, correct and make available its corrected HMDA data from 2012-2014. Release. Full Order.

Rating Agency Developments

 

On March 16, 2017, DBRS issued a report entitled General Corporate Methodology. Report.

On March 16, 2017, DBRS issued a report entitled North American Single-Asset/Single-Borrower Methodology. Report.

On March 16, 2017, Fitch issued a report entitled U.S. Auto ABS Quarterly Index Report. Report.

On March 16, 2017, Moody’s issued a report entitled Global Alcoholic Beverage Industry. Report.

On March 16, 2017, Moody’s issued a report entitled Regulated Electric and Gas Networks. Report.

On March 15, 2017, DBRS issued a report entitled Rating North American CMBS Interest-Only Certificates. Report.

On March 10, 2017, Fitch issued a report entitled Criteria for Analyzing Large Loans in CMBS. Report.

On March 10, 2017, Fitch issued a report entitled Global Non-Bank Financial Institutions Rating Criteria. Report.

On March 10, 2017, Moody’s issued a report entitled Financial Guarantors. Report.

On March 8, 2017, Fitch issued a report entitled Updated U.S. Auto Lease ABS Rating Criteria. Release.