Alexander Radisich

Associate

Los Angeles


Read full biography at www.orrick.com

Alex Radisich, an associate in Orrick's Los Angeles office, is a member of the firm's Structured Finance and Banking and Finance Groups. 

During law school, Alex served as a judicial extern to the Honorable Judge Harry Pregerson of the United States Court of Appeals for the Ninth Circuit, and as a law clerk on the Senate Judiciary Committee for Senator Dianne Feinstein.

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Posts by: Alexander Radisich

CFPB Issues Final Rule Temporarily Raising Reporting Threshold for Home Equity Loans Under Home Mortgage Act Rules

 

On August 24, 2017, the Consumer Financial Protection Bureau (the “CFPB“) issued a new rule that amends the 2015 updates to the Home Mortgage Act (“HMDA“) rules. Under the HMDA rules that are scheduled to take effect in January 2018, financial institutions would have been required to report home‑equity lines of credit if they made 100 such loans in each of the last two years. The new final rule issued by the CFPB increases the threshold from 100 loans to 500 loans through 2018 and 2019 while the CFPB considers whether to make a permanent adjustment. Read more here.

Rating Agency Developments

 

On August 31, 2017, S&P published its methodology for rating U.S. Credit Card Securitizations. Report.

On August 31, 2017, S&P published a Table of Contents to its Structured Finance Criteria. Report.

On August 31, 2017, Moody’s published its approach to rating SME Balance Sheet Securitizations. Report.

On August 31, 2017, Moody’s published a proposed revised framework to its approach to Mapping Ratings and Scores Provided by Third-Party Entities. Report.

On August 31, 2017, Moody’s published its approach to rating Corporate Synthetic Collateralized Loan Obligations. Report.

On August 31, 2017, Moody’s published its global approach to rating Collateralized Loan Obligations. Report.

On August 29, 2017, Moody’s published its global approach to rating Municipal and Sub-Sovereign CDOs. Report.

On August 24, 2017, DBRS published an update to its rating methodology for Companies in the Mining Industry. Report.

On August 24, 2017, DBRS published an update to its rating methodology for Container Terminal Operators. Report.

On August 24, 2017, Fitch published an update to its rating criteria for Global Rental Fleet ABS. Release.

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 and FDIC Post Resolution Plans for Eight Major Financial Firms

 

On July 5, 2017, the Federal Reserve Board (the “Board“) and the Federal Deposit Insurance Corporation (“FDIC“) posted the public portions of the annual resolution plans, commonly known as living wills, for eight of the largest financial firms in the US. Although the eight firms this—is Bank of America Corporation, The Bank of New York Mellon Corporation, Citigroup Inc., The Goldman Sachs Group, Inc., JPMorgan Chase & Co., Morgan Stanley, State Street Corporation and Wells Fargo & Company—were required to submit their plans on July 1, 2017, the Board and FDIC also announced that they were extending the deadline for American International Group, Inc. (AIG) and Prudential Financial, Inc. to submit their next resolution plans from December 17, 2017 to December 18, 2017. Report. Press Release.

SEC to Allow Issuers to File Draft Initial Registration Statements on a Nonpublic Basis

 

On June 29, 2017, the Securities and Exchange Commission (“SEC“) announced that it would begin to allow issuers to file draft initial registration statements under the Securities Act of 1933 (the “Securities Act“) on a nonpublic basis. Any company, foreign or domestic, will be allowed to submit registration statements for nonpublic review, similar to the benefit granted to emerging growth companies under the Jumpstart Our Business Startups Act (JOBS) as long as it confirms in a cover letter that it will publicly file its registration statement at least 15 days prior to any road show or, in the absence thereof, at least 15 days prior to the requested effective date of its registration statement. The SEC also announced that it would begin to accept draft registration statements submitted prior to the end of the 12th month following the effective date of an issuer’s initial Securities Act registration statement, or its registration statement under Section 12(b) of the Securities and Exchange Act of 1934, for nonpublic review so long as the issuer confirms in a cover letter that it will publicly file its registration statement and nonpublic draft submission on EDGAR at least 48 hours prior to any requested effective time and date. Report. Press Release.

Rating Agency Developments

 

On May 10, 2017, DBRS published its general corporate rating methodology. Report.

On May 10, 2017, DBRS published its methodology for rating companies in the capital goods dealership industry. Report.

On May 10, 2017, DBRS published its criteria for evaluating corporate governance. Report.

On May 10, 2017, Moody’s published its ratings methodology for assessing companies in the independent exploration and production industry. Report.

On May 9, 2017, DBRS published an update to its master surveillance methodology for reviewing its ratings of Canadian structured finance and covered bond transactions. Report.

On May 9, 2017, Moody’s published its ratings methodology for assessing companies in the global surface transportation and logistics industry. Report.

On May 9, 2017, Moody’s published an update to its ratings methodology regarding its approach to pre-refunded and escrow-backed bonds. Report.

On May 8, 2017, DBRS published its methodology for rating Canadian public pension funds and related exclusive asset managers. Report.

On May 5, 2017, DBRS published its methodology for rating credit funds. Report.

On May 5, 2017, Moody’s published its ratings methodology for assessing companies in the global oilfield services industry. Report.

OCC Provides Additional Details to Evaluate Charter Applications From fintech Companies

 

On March 15, 2017, the Office of the Comptroller of the Currency (“OCC“) issued a “Draft Licensing Manual Supplement for Evaluating Charter Applications from Financial Technology Companies,” which provides additional details on the evaluation of national bank charter applications from financial technology (“fintech“) companies that engage in the business of banking. The supplement explains how the OCC will apply the licensing standards and requirements in existing regulations and policies to fintech companies applying for special purpose national bank charters. The supplement also describes unique factors that the agency will consider in evaluating applications from fintech companies; expectations for promoting fair access, fair treatment and financial inclusion; and the agency’s approach to supervising those fintech companies that become national banks. Release. Manual Supplement.

Nationstar Mortgage to Pay $1.75 Million Penalty for HMDA Violations

 

On March 15, 2017, the Consumer Financial Protection Bureau (“CFPB“) ordered Nationstar Mortgage LLC (“Nationstar“) to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (“HMDA“) by consistently failing to accurately report data about mortgage transactions between 2012 through 2014. The $1.75 million civil penalty is the largest HMDA penalty imposed by the CFPB to date. The CFPB found that (1) Nationstar’s HMDA compliance systems were flawed and generated mortgage lending data with significant, preventable errors; (2) Nationstar failed to maintain detailed HMDA data collection and validation procedures and failed to implement adequate compliance procedures; and (3) Nationstar failed to consistently define data among its various lines of business. In addition to the civil penalty, the CFPB ordered Nationstar to develop and implement an effective compliance management system and to review, correct and make available its corrected HMDA data from 2012-2014. Release. Full Order.

Rating Agency Developments

 

On March 16, 2017, DBRS issued a report entitled General Corporate Methodology. Report.

On March 16, 2017, DBRS issued a report entitled North American Single-Asset/Single-Borrower Methodology. Report.

On March 16, 2017, Fitch issued a report entitled U.S. Auto ABS Quarterly Index Report. Report.

On March 16, 2017, Moody’s issued a report entitled Global Alcoholic Beverage Industry. Report.

On March 16, 2017, Moody’s issued a report entitled Regulated Electric and Gas Networks. Report.

On March 15, 2017, DBRS issued a report entitled Rating North American CMBS Interest-Only Certificates. Report.

On March 10, 2017, Fitch issued a report entitled Criteria for Analyzing Large Loans in CMBS. Report.

On March 10, 2017, Fitch issued a report entitled Global Non-Bank Financial Institutions Rating Criteria. Report.

On March 10, 2017, Moody’s issued a report entitled Financial Guarantors. Report.

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