SueAnn Yue, an attorney in the Los Angeles office, is a member of the Structured Finance Group.

SueAnn represents issuers, sponsors, placement agents, servicers, underwriters, and other market participants in connection with both public offerings and private placements, asset acquisitions and sales and the negotiation of lending facilities.

Her practice encompasses a variety of asset-backed securities, including credit and charge card receivables, residential mortgage-backed securities (RMBS), agency and government sponsored mortgage loans, and tax lien-backed securities.

SueAnn advises clients on the implications of financial markets regulation, including the implementation of the Dodd-Frank Act. SueAnn is also an editor of Orrick's Financial Industry Week in Review.

Array

Posts by: SueAnn Yue

Rating Agency Developments

 

On April 4, 2017, DBRS updated its methodology for rating U.S. residential mortgage-backed securities (RMBS). Report.

On April 4, 2017, DBRS published its methodology for rating U.S. Property Assessed Clean Energy (PACE) securitizations. Report.

On April 4, 2017, DBRS published its methodology for rating structured finance CDO restructurings. Report.

On April 4, 2017, Moody’s published its ratings methodology for assessing companies in the equipment and transportation rental industry. Report.

On March 31, 2017, DBRS published its master methodology for assessing European structured finance. Report.

On March 30, 2017, Fitch updated its rating criteria for U.S. public finance tender option bonds. Report.

On March 30, 2017, Moody’s updated its ratings methodology for market value collateralized loan obligations (MV CLOs). Report.

CFTC Issues Time-Limited No-Action Relief for Aggregation Notice Filings for Position Limits

 

On February 6, 2017, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued a time-limited no-action letter providing relief for notice filing failures that relied on certain aggregation exemptions from federal position limit levels. The letter provides temporary relief from February 14, 2017 to August 14, 2017. Press Release. No-Action Letter.

Rating Agency Developments

 

On February 8, 2017, Fitch updated its rating criteria for U.S. municipal short-term debt. Report.

On February 8, 2017, Fitch updated its criteria assumptions for analyzing securities backed by UK residential mortgage loans. Report.

On February 6, 2017, DBRS published its ratings methodology for certain critical obligations. Report.

On February 4, 2017, Kroll published its ratings methodology for securitizations composed of pools of multiple loans secured by one or more commercial real estate (CRE) properties. Report.

On February 4, 2017, Kroll published its ratings methodology for single-family rental securitizations. Report.

Rating Agency Developments

 

On January 18, 2017, Moody’s issued a report entitled Hybrid Equity Credit. Report.

On January 17, 2017, DBRS issued a report entitled Rating North American CMBS Interest‑Only Certificates – Request for Comment. Report.

On January 17, 2017, Fitch issued a report entitled Fitch Publishes Updated Global Dealer Floorplan Rating Criteria. Release.

On January 17, 2017, Fitch issued a report entitled Fitch Updates Criteria for Variable-Rate Demand Obligations and Commercial Paper. Release.

On January 13, 2017, DBRS issued a report entitled Structured Finance Flow‑Through Ratings. Report.

On January 13, 2017, Fitch issued a report entitled Fitch Updates Rating Investment Holding Companies Criteria. Report.

On January 10, 2017, DBRS published its ratings methodology for European CMBS. Report.

On January 9, 2017, Moody’s published its ratings methodology for fleet lease‑backed ABS. Report.

On January 9, 2017, Fitch updated its ratings criteria for pre‑refunded U.S. municipal bonds. Report.

On January 5, 2017, Fitch updated its asset analysis criteria for covered bonds and CDOs of public entities. Report.

OCC Publishes Final Rule on Expanding Examination Cycle Eligibility

 

On January 6, 2017, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation published a final rule amending the regulations governing eligibility for the 18‑month on‑site examination cycle, which broadened the eligibility requirements to include certain qualifying banks with less than $1 billion in total assets. The final rule adopted, without change, each of the provisions of the interim final rule published on February 29, 2016. Release.

CTFC Approves Re-Proposal of Position Limits Regulation

 

On December 5, 2016, the U.S. Commodity Futures Trading Commission (“CFTC“) unanimously approved to re‑propose rules that implement limits on speculative futures and swap positions. Separately, the CFTC also approved final rules on aggregation of positions, a component of the existing position limits framework. The comment period ends 60 days after publication of the re-proposal in the Federal Register. Release.

OCC to Move Forward With Considering Fintech Charter Applications

 

On December 2, 2016, Comptroller of the Currency Thomas J. Curry announced that the Office of the Comptroller of the Currency (“OCC“) would move forward with considering applications from fintech companies that conduct at least one of three core banking activities (i.e., receiving deposits, paying checks or lending money) to become special purpose national banks. Fintech companies will have the option to seek a charter, and the OCC will evaluate applicants to ensure they have a reasonable chance of success, appropriate risk management, effective consumer protection and strong capital and liquidity.

The OCC simultaneously published a paper discussing the issues and conditions that the agency will consider in granting special purpose national bank charters. Comments to the paper may be submitted through January 15, 2017. For further discussion relating to the announcement, please see “National Bank Charters for Fintech Companies.” Orrick Alert. Release. White Paper.

CTFC Approves Minimal Capital Requirements for Swap Dealers and Major Swap Participants

 

On December 2, 2016, the U.S. Commodity Futures Trading Commission (CFTC) unanimously approved proposed rules that establish minimum capital requirements for swap dealers and major swap participants. The proposed rules set out minimum levels of qualifying capital for swap deals and major swap participants that are not subject to the capital rules of a prudential regulator. The comment period ends 90 days after publication of the proposal in the Federal Register. Release.

Rating Agency Developments

 

On December 7, 2016, Moody’s published its ratings methodology for sustainable net cash flow and value for CMBS and CRE CDO CLO real estate collateral in the Americas and ex-Japan Asia Pacific. Report.

On December 6, 2016, DBRS published its methodology for rating European covered bonds. Report. Addendum.

On December 1, 2016, DBRS updated its master ratings methodology for U.S. asset-backed securitizations (“ABS“). Report.

On December 1, 2016, DBRS updated its ratings methodology for U.S. structured finance transactions. Report.

On December 1, 2016, DBRS updated its methodology for evaluating U.S. ABS originators. Report.

On December 1, 2016, DBRS updated its methodology for evaluating U.S. ABS servicers. Report.

On December 1, 2016, Fitch updated its U.S. RMBS master rating criteria. Report.

On December 1, 2016, Fitch updated and merged its ratings criteria for analyzing U.S. RMBS backed by seasoned performing, re‑performing and non‑performing loans purchased in the secondary market and issued starting in 2014. Report.

On December 1, 2016, Fitch updated its global consumer ABS rating criteria for analyzing ABS backed by consumer receivables globally. Report.

On December 1, 2016, Fitch updated its ratings criteria for analyzing large loans in CMBS. Report.

Rating Agency Developments

 

On November 9, 2016, Fitch updated its ratings criteria for analyzing U.S. wireless tower transactions. Report.

On November 8, 2016, DBRS published its ratings methodology for Canadian trade receivable securitization transactions. Report.

On November 8, 2016, DBRS published its ratings methodology for Canadian residential mortgages, home equity lines of credit and reverse mortgages. Report.

On November 8, 2016, DBRS published its ratings methodology for Canadian credit card and personal line of credit securitizations. Report.

On November 4, 2016, Fitch updated its ratings criteria for charter schools. Report.