CFTC Provides Relief in Connection with Erroneous Swap Trades and Swap Trade Confirmations

On April 22, the CFTC issued two no action letters providing relief intended to support the development of swap execution facilities (SEFs) and the trading of swaps on SEFs and designated contract markets (DCMs).  The first no action letter provides relief to SEFs and DCMs from regulations to allow for the correction of trades voided as a result of clerical or operational errors or errors discovered after a trade has been cleared.  The second no action letter provides relief to SEFs from certain requirements concerning trade confirmations required from SEFs for non-cleared swaps.  ReleaseNo Action Letter #1.   No Action Letter #2.

Federal Reserve Board Releases Additional Information on the LISCC Supervisory Program

On April 17, the Federal Reserve Board published a Supervision and Regulation Letter containing additional information on the operating structure of the Large Institution Supervision Coordinating Committee (LISCC) supervisory program, which was established in 2010 to oversee and supervise certain large and systemically important financial institutions.  ReleaseSupervision and Regulation Letter.

Rating Agency Developments

On April 23, Fitch released its updated criteria for rating operational risk of U.S. servicers of RMBS and small balance commercial securitiesReport.

On April 23, Fitch released its updated criteria for rating operational risk of servicers of various structured finance products, including RMBS, CMBS, and ABS.  Report.

On April 22, Moody’s released its rating methodology for monitoring scheduled amortization UK student loan-backed securities.   Report.

On April 21, Fitch released its updated criteria for analyzing trust-preferred CDOsReport.

On April 17, DBRS released its updated criteria for commercial paper liquidity support for non-bank issuers. Report.

On April 17, DBRS released its criteria for rating market-linked securitiesReport.

SEC Adopts Updated EDGAR Filer Manual

On April 13, the SEC adopted revisions to EDGAR Filer Manual and related rules to reflect updates to the EDGAR system. The updates are being made primarily to support the 2015 US GAAP financial reporting and 2015 EXCH taxonomies; add new form types for registration of Security-based swap data repositories (SDR); revise the Form ID Application Confirmation screen; remove references to the Paper Form ID; and revise Item 1 on submission form type MA-A.  Final Rule.

Federal Reserve Request Comment on Proposed Amendments to Regulation D

On April 13, the Federal Reserve Board requested public comment on proposed amendments to Regulation D (Reserve Requirements of Depository Institutions) making technical changes to the calculation of interest payments on certain balances maintained by depository institutions at Federal Reserve Banks. The proposed amendments are a matter of prudent planning and have no implications for the near-term conduct of monetary policy.  ReleaseFederal Register Notice.

Rating Agency Developments

On April 7, DBRS released its Cash Flow Assumptions for Corporate Credit Securitizations Methodology. Report.

On April 7, DBRS released its Rating CLOs and CDOs of Large Corporate Credit Methodology. Report.

On April 7, Fitch released its Updated Global Structured Finance & Covered Bonds Criteria Hierarchy. Report.

On April 6, Fitch updated its U.S. RMBS Cash Flow Analysis Criteria. Report.

On April 6, S&P released its Rating Methodology And Assumptions For Global CMBS. Report.

On April 2, DBRS added a Film Rights Appendix to its DBRS Master U.S. ABS Surveillance Methodology. Report.

On April 2, DBRS released its Rating U.S. Film Rights Securitization Methodology. Report.

On April 1, Moody’s updated its Rating Methodology for Mortgage Insurers. Report.

On March 30, S&P released its Ireland RMBS Methodology And Assumptions, effective April 13, 2015. Report.





Rating Agency Developments

On March 27, DBRS released its updated methodology for rating North American commercial mortgage-backed securities (CMBS).  Report.

On March 27, Fitch released its updated criteria for analyzing U.S. wireless tower transactionsReport.

On March 31, Fitch released its updated criteria for analyzing loans securing residential mortgage-backed securities (RMBS) under the ability-to-repay and qualified mortgage standards that the Bureau of Consumer Financial Protection adopted as part of its amendments to Regulation Z under the Truth in Lending Act.  Report.

On April 1, DBRS released its updated methodology for the surveillance of European structured finance and covered bonds transactionsReport.