Ashley Halvorsen

Associate

Los Angeles


Read full biography at www.orrick.com

Ashley Halvorsen is an associate in the Structured Finance group in the Los Angeles office.

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Posts by: Ashley Halvorsen

Temporary Policy Allowing Purchase of Qualified Loans in Forbearance is Extended

 

On October 21, the Federal Housing Finance Agency (FHFA) extended a policy allowing certain single-family mortgages in forbearance to be delivered to Fannie Mae and Freddie Mac for borrowers who sought payment forbearance due to the impact of COVID-19 shortly after closing on their single-family loan. Normally, mortgage loans in either forbearance or delinquency are ineligible for delivery. The policy was extended for loans originated through November 30, 2020. Release.

Agencies Issue a Final Rule to Strengthen Resilience of Large Banks

 

On October 20, the federal bank regulatory agencies finalized the net stable funding ratio rule, which requires large banks to maintain a minimum level of stable funding relative to each institution’s assets, derivatives, and commitments over a one-year period. The rule aims to strengthen the resilience of large banks and their ability to lend across economic conditions. Release.

Agencies Finalize Rule to Reduce the Impact of Large Bank Failures

 

On October 20, the federal bank regulatory agencies finalized a rule to limit the impact of the failure of large banking organizations. The final rule requires a more stringent regulatory capital treatment for holdings of total loss-absorbing capacity (TLAC) debt, which is issued by U.S. global systemically important bank holding companies (GSIBs). This is intended to discourage large banking organizations from purchasing such debt and reduce the interconnectedness between large banking organizations. The final rule is effective on April 1, 2021. Release. 

Adverse Market Refinance Fee Implementation Now December 1

 

Fannie Mae and Freddie Mac have postponed the implementation date of their Adverse Market Refinance Fee from September 1 to December 1, per direction from the Federal Housing Finance Agency (FHFA). Certain Fannie Mae and Freddie Mac loans will also be exempt from the Adverse Market Refinance Fee. The fee is intended to cover costs to Fannie Mae and Freddie Mac associated with protections extended to renters and borrowers affected by COVID-19. Release.

Rating Agency Developments (August 24 – September 1)

 

On September 1, KBRA published its Structured Finance: CMBS report titled Coronavirus (COVID-19): Affiliate of On-Demand Office Provider Regus Files for Bankruptcy—CMBS Exposure Examined. Report.

On September 1, DBRS Morningstar published its methodology titled DBRS Morningstar Global Structured Finance Related Methodologies. Methodology.

On August 28, DBRS Morningstar published its methodology titled U.S. Residential Mortgage Servicer Rankings. Methodology.

On August 28, DBRS Morningstar published its methodology titled U.S. Residential Mortgage Originator Rankings. Methodology.

On August 28, KBRA published its report titled CMBS/RMBS: Single-Borrower SFR Comprehensive Surveillance. Report.

On August 27, KBRA published its rating methodology titled ABS: Global Auto Loan ABS Rating. Methodology.

On August 24, KBRA published its research report titled Structured Credit: Coronavirus (COVID-19): U.S. BSL CLO Sector Exposure Map: July 2020. Report.

SEC Modernizes the Accredited Investor Definition

 

The Securities and Exchange Commission (SEC) amended the definition of “accredited investor” to more effectively identify institutional and individual investors that have the knowledge and expertise to participate in private capital markets. The amendments allow individuals to qualify as accredited investors based on measures of financial sophistication, including professional knowledge, experience or certification, as well as existing tests for income or net worth. The updates to the definition also expand the entities that may qualify as accredited investors. Release.

FHFA Provides Tenant Protections

 

On June 29, the Federal Housing Finance Agency (FHFA) provided additional protections for owners and renters of multifamily properties by allowing servicers to extend existing forbearance agreements for up to three months, for a total forbearance of up to six months for multifamily property owners with loans backed by Fannie Mae and Freddie Mac. Borrower may qualify for up to 24 months to repay the missed payments once the forbearance period concludes, and borrowers must comply with additional tenant protections during this period. Release.

Financial Regulators Modify Volcker Rule

 

On June 25, financial regulatory agencies modified the Volcker rule’s prohibition on banking entities investing in or sponsoring hedge funds or private equity funds, known as covered funds. The final rule permits banking entities to offer financial services and engage in other activities that fall outside of the issues that the rule was intended to address, and it streamlines the covered funds portion of the rule. The rule will be effective as of October 1. Release. Final Rule.

Agencies Finalize Amendments to Swap Margin Rule

 

On June 25, federal agencies finalized a rule that updates margin and capital requirements for banks and other entities with significant swap activities. The updated rule no longer requires entities that are part of the same banking organization to hold a specific amount of initial margin for uncleared swaps with each other, such swaps being known as inter-affiliate swaps. The changes to the swap margin rule also provide additional flexibility to allocate collateral internally. The final rule is intended to facilitate risk management and maintain existing safeguards. Release. Final Rule.

Rating Agency Developments (June 18 – June 30)

 

On June 30, Fitch published its criteria for Covered Bonds RatingCriteria.

On June 30, DBRS Morningstar published its updated methodology for U.S. ABS General RatingsMethodology.

On June 26, Moody’s published its updated methodology for Catastrophe Bonds. Methodology.

On June 26, KBRA published a ­­­­­­­­­­­­­­­release titled KBRA Assigns Ratings to BANK 2020-BNK27. Release.

On June 25, KBRA published a report titled Public Finance: Coronavirus (COVID-19): Unemployment Improves in All but Six States. Report.

On June 24, Moody’s published its revised methodology for rating Credit Card Receivables-Backed Securities. Methodology.

On June 24, Moody’s published its revised methodology for rating Credit Tenant Lease and Comparable Lease Financings. Methodology.

On June 19, Fitch published its revised criteria for rating Future Flow Securitizations. Criteria.

On June 19, Fitch published its revised criteria for rating CMBS Large Loans. Criteria.

On June 19, Moody’s published its revised methodology for rating Floorplan Asset-Backed Securities. Methodology.

On June 19, Moody’s published its revised methodology for rating Repackaged Securities. Methodology.

On June 18, Moody’s published its revised methodology for rating Covered Bonds. Methodology.