Ashley Halvorsen

Managing Associate

Los Angeles

ahalvorsen@orrick.com

Read full biography at www.orrick.com

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

Ashley represents issuers, underwriters, servicers, lenders, and other market participants in connection with securitizations, asset financings and sales, and negotiation of lending facilities. Ashley's practice encompasses a variety of asset-backed securities, including residential mortgage-backed securities and credit and charge card receivables.

Posts by: Ashley Halvorsen

CFPB Releases Qualified Mortgage ANPR

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The Consumer Financial Protection Bureau (CFPB) is soliciting comments on possible amendments to the Ability to Repay/Qualified Mortgage (ATR/QM) Rule. In particular, the CFPB is considering revising the current definition of a qualified mortgage under the Truth in Lending Act to use alternative methods to debt-to-income ratio to measure a consumer’s financial capacity. These considerations are prompted by the January 2021 expiration of rules in which certain mortgage loans eligible for purchase or guarantee by Freddie Mac or Fannie Mae, which do not otherwise meet the debt-to-income ratio requirements, fall under the current definition of qualified mortgage. Release.

SEC Adopts Rules and Interpretations to Enhance Protections and Preserve Choice for Retail Investors in Their Relationships with Financial Professionals

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The U.S. Securities and Exchange Commission (SEC) adopted and clarified a number of rules intended to improve the relationships between retail investors, investor advisers and broker-investors, while also maintaining retail investors’ access to investment services and products. Under Regulation Best Interest, broker-dealers must act in the best interest of a retail customer when recommending any securities transaction or investment strategy. The Form CRS Relationship Summary requires registered investment advisers and broker-dealers to provide retail investors with easily comprehensible information about their relationship with their financial professional. Lastly, the SEC clarified investment advisers’ fiduciary duties and the activities that trigger a broker-dealer to be considered an investor adviser under the Advisers Act. Press Release. For further detail on the subject, read an analysis from Orrick’s Securities Litigation team here.

OCC Extends Dodd-Frank Act Stress Test Requirements Through November 25

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The Office of the Comptroller of the Currency (OCC) announced that the deadline to comply with Dodd-Frank Act Stress Test (DFAST) requirements will be extended to November 25, and thereafter will be discontinued. The OCC believes that sufficient stress testing programs have been adopted and integrated into the risk management policies of banks and federal savings institutions to which the DFAST rules apply. Press Release.

Rating Agency Developments

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On June 5, Fitch published a methodology for U.S. RMBS Seasoned and Reperforming Loans. Methodology.

On June 4, Fitch published a methodology for APAC Residential Mortgages. Methodology.

On June 3, Moody’s published its updated methodology for Resecuritizations. Methodology.

On May 31, Fitch published its updated methodology for European RMBS. Methodology.

On May 31, Fitch published a methodology for EMEA CMBS and CRE Loans. Methodology.

On May 31, S&P published its updated methodology for Global Equipment ABS. Methodology.

On May 30, Moody’s published its updated methodology for Reverse Mortgage Securitizations. Methodology.

Agencies Issue Final Rule Regarding the Treatment of Certain Municipal Obligations as High-Quality Liquid Assets

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The federal bank regulatory agencies issued a final rule requiring that certain municipal obligations be treated as high-quality liquid assets if the municipal obligation is “liquid and readily marketable” and “investment grade” under the liquidity coverage ratio rules. Press Release.

Rating Agency Developments

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On January 30, DBRS published a report entitled: Master European Structured Finance Surveillance Methodology. Report.

On January 30, S&P published a report entitled: Incorporating Sovereign Risk in Rating Structured Finance Securities: Methodology and Assumptions. Release.

On January 29, Moody’s published a report entitled: Moody’s Approach to Assessing Counterparty Risks in Structured Finance. Release.

On January 28, DBRS published a report entitled: DBRS North American Commercial Real Estate Property Analysis Criteria. Report.

On January 25, S&P published a report entitled: Global Methodology and Assumptions: Assessing Pools of Residential Loans. Release.

Shared National Credit Review Finds Some Improvement in Credit Quality, While Risk Remains Elevated in Leveraged Loans

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On January 25, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency released a report reviewing Shared National Credit Loans, which found that risk associated with large syndicated loans has declined, while the risk associated with leveraged lending has not improved. The report encourages banks to update credit risk management policies according to the current risk climate. Release.