Amy Chan

Managing Associate

New York


Read full biography at www.orrick.com
Amy Chan, an associate in the New York office, is a member of the Structured Finance Group. Amy represents a variety of market participants, including sponsors, issuers and underwriters, in public and private offerings of commercial mortgage-backed securities.ArrayArray

Posts by: Amy Chan

Federal Banking Agencies Propose Extension of Certain Capital Rule Transitions

 

On August 22, 2017, in preparation for a forthcoming proposal that would simplify regulatory capital requirements, federal banking regulators proposed a rule that would extend the existing transitional capital treatment for certain regulatory capital deductions and risk weights. The extension would apply to banking organizations that are not subject to the agencies’ advanced approach to capital rules, which are generally those with less than $250 billion in total consolidated assets and less than $10 billion in total foreign exposure. Comments on this proposal will be accepted for 30 days after publication in the Federal Register. FDIC Press Release. Federal Reserve Press Release. OCC Press Release. Proposal.

Rating Agency Developments

 

On August 23, 2017, DBRS published a report entitled Rating Companies in the Oil and Gas and Oilfield Services Industries. Report.

On August 21, 2017, Moody’s published a report entitled Government-Related Issuers. Report.

On August 18, 2017, DBRS published a report entitled Rating Companies in the Communications Industry. Report.

On August 18, 2017, DBRS published a report entitled Rating Companies in the Consumer Products Industry. Report.

On August 18, 2017, DBRS published a report entitled Rating Companies in the Merchandising Industry. Report.

On August 17, 2017, Fitch published a report entitled U.S. Military Housing Rating Criteria. Report.

Rating Agency Developments

 

On July 7, 2017, Kroll published its Research Recap for Q2 2017. Here are several articles of interest:

On June 29, 2017, DBRS published an update to its rating methodology for U.S. equipment lease and loan securitizations. Report.

On June 29, 2017, Fitch published an update to its rating criteria for insurance-linked securities. Release.

On June 28, 2017, Fitch published a report entitled U.S. State Housing Finance Agencies: Single-Family Mortgage Program Rating Criteria. Report.

On June 28, 2017, Fitch published a report entitled U.S. RMBS Surveillance and Re-REMIC Rating Criteria. Report.

On June 23, 2017, Moody’s published a report entitled Regulated Electric and Gas Utilities. Report.

On June 23, 2017, S&P issued a report entitled RMBS: Methodology And Assumptions: Assessing Pools Of Residential Loans In Austria, Denmark, Germany, And Sweden. Report.

On June 22, 2017, S&P issued a report entitled ABS: Global Methodology And Assumptions For Corporate Securitizations. Report.

On June 22, 2017, Fitch published a report entitled U.S. RMBS Rating Criteria. Report.

On June 22, 2017, Fitch published a report entitled EMEA CMBS and CRE Loan Rating Criteria. Report.

Federal Reserve Releases Results of CCAR

 

On June 28, 2017, the Federal Reserve Board announced that it has completed its annual review of the capital planning processes and capital adequacy of the largest U.S.-based bank holding companies and did not object to the capital plans of all 34 bank holding companies participating in the Comprehensive Capital Analysis and Review (CCAR). However, the Federal Reserve Board is requiring one firm to address weaknesses in its capital planning process and resubmit its capital plan by the end of 2017. Report. Press Release.

Federal Reserve Board Releases Results of Supervisory Bank Stress Tests

 

On June 22, 2017, the Federal Reserve Board released the results of its annual supervisory stress tests conducted on 34 bank holding companies. According to the results, the nation’s largest bank holding companies have strong capital levels and retain their ability to lend to households and businesses during a severe recession. The supervisory stress tests are carried out pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act and is one component of the Federal Reserve’s analysis during the Comprehensive Capital Analysis and Review (CCAR), which is an annual exercise to evaluate the capital planning processes and capital adequacy of large bank holding companies. Report. Press Release.

CFTC Proposes to Amend Rules Governing Chief Compliance Officer Duties and Annual Reports for Certain Registrants

 

On May 3, 2017, the U.S. Commodity Futures Trading Commission (CFTC) announced that it will publish in the Federal Register proposed amendments to Part 3 of its regulations. The proposed amendments would (1) define “senior officer” in Regulation 3.1; (2) clarify the duties of a Chief Compliance Officer (“CCO“) of a futures commission merchant, swap dealer, or major swap participant; and (3) modify the CCO annual report’s content and submission requirements. The comment period ends 60 days after the proposal’s publication in the Federal Register. Press Release. Proposal.

Rating Agency Developments

 

On May 3, 2017, DBRS issued a report entitled Rating Canadian Public Hospitals. Report.

On May 3, 2017, Fitch issued a report entitled Global Structured Finance Rating Criteria. Report.

On May 3, 2017, Moody’s proposed limited updates to its approach for rating US and Canadian conduit/fusion CMBS. Report.

On May 3, 2017, Moody’s proposed changes to its approach to rating asset-backed commercial paper. Report.

On April 28, 2017, DBRS issued a report entitled Operational Risk Assessments for Canadian Structured Finance. Report.

On April 27, 2017, Fitch issued a report entitled Non-Financial Corporates Hybrids Treatment and Notching Criteria. Report.

On April 27, 2017, Fitch issued a report entitled Global Money Market Fund Rating Criteria. Report.

Rating Agency Developments

 

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

On March 7, 2017, DBRS issued a report entitled Mapping Financial Institution Internal Ratings to DBRS Ratings for Global Structured Credit Transactions. Report.

On March 7, 2017, Fitch issued a report entitled National Scale Ratings Criteria. Report.

On March 7, 2017, Moody’s updated its rating criteria for variable rate instruments supported by conditional liquidity facilities. Report.

On March 6, 2017, Fitch issued a report entitled Criteria for Analyzing Multiborrower U.S. and Canadian Commercial Mortgage Transactions. Report.

On March 6, 2017, Moody’s updated its rating criteria for gas prepayment bonds. Report.

On March 3, 2017, DBRS issued a report entitled Rating Public-Private Partnerships. Report.

On March 3, 2017, Fitch issued a report entitled SME Balance Sheet Securitisation Rating Criteria. Report.

On March 3, 2017, Fitch issued a report entitled North America and Asia-Pacific Multiborrower CMBS Surveillance Criteria. Report.

On March 2, 2017, DBRS issued a report entitled Rating Sports Franchises and Stadium Financings. Report.