S. Chris Min

Of Counsel

New York


Read full biography at www.orrick.com
Sie Ne Chris Min, an of counsel in the New York office, is a member of the Structured Finance Group.  Chris represents issuers, sponsors, underwriters and placement agents in connection with public offerings and private placements of various asset-backed securities.

She has broad experience with a number of asset classes, including credit card receivables, auto loan receivables, municipal bonds and residential mortgages.   

Posts by: Chris Min

Rating Agency Developments

On June 26, Fitch released its updated criteria for rating credit card asset-backed securitiesReport.

On June 23, Fitch released its updated criteria for rating thermal power projectsReport.

On June 23, Fitch released its updated global criteria assumptions for analyzing the use of lender’s mortgage insurance in RMBS transactionsReport.

On June 23, Moody’s published its updated methodology for rating future receivables transactionsReport.

On June 22, Moody’s published its revised methodology for rating securities backed by utility recovery chargesReport.

On June 16, Moody’s published its revised methodology for rating counterparty instrument ratingReport.

On June 16, Moody’s published its revised methodology for rating credit card receivables-backed securitiesReport.

On June 15, Moody’s published its revised methodology for rating repackaged securitiesReport.

On June 15, Moody’s published its updated methodology for financial statement adjustmentsReport.

On June 12, Fitch released its updated criteria for rating U.S. RMBS transactionsReport

On June 12, Fitch released its updated criteria for rating issuers that use Distressed Debt ExchangesReport.

On June 12, KBRA released its methodology for rating bonds issued by public sector entities and secured by revenues generated form a tax assessment on real propertyReport.

On June 10, DBRS released its updated methodology for rating U.S. structured finance transactions backed by direct pay letter of creditReport.

On June 9, DBRS published updated versions of its various methodologies for structured finance productsPress Release.

On June 9, DBRS published its methodology setting forth consistent approach for application of interest rate stresses applied across all U.S. structured finance methodologiesReport.

On June 9, Fitch released its updated criteria for rating U.S. non-profit hospitals and health systemsReport.

CFPB Publishes Final Rule that Allows its Supervision of Nonbank Auto Finance Companies

On June 10, CFPB published a final rule today that allows the agency to begin supervising large, nonbank auto finance companies for the first time.  The newly adopted rule will extend the CFPB’s supervision to any nonbank auto finance company that makes, acquires or refinances 10,000 or more loans or leases per year.  The CFPB also released the examination procedures that will be used to ensure the auto finance companies’ compliance with the law.  Press ReleaseFinal RuleExamination Procedures.

SEC Requests Public Comments on Exchange-Traded Products

On June 12, the Securities and Exchange Commission announced that it is seeking public comments on issues relating to listing and trading of new, novel, or complex exchange-traded products.  The request for comment addresses key issues that arise when exemptions are sought by a market participant to trade a new product or when a securities exchange seeks to establish standards for listing new products.  The comments may be submitted by August 17, 2015Request for Comments.

CFTC Extends No-Action Relief to Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations

On June 15, CFTC Division of Market Oversight published a letter extending the time-limited relief provided by previously issued no-action letter 14-90, expiring on June 30, 2015, to  June 30, 2016.  The relief applies to the obligation of Swap Dealers and Major Swap Participants to report valuation data for cleared swaps pursuant to section 45.4(b)(2)(ii) of CFTC’s regulations.  Press ReleaseStaff Letter.

FDIC, Federal Reserve and Office of Comptroller of the Currency Reiterate Annual Public Disclosure Requirements for Medium-Sized Financial Companies Under Dodd-Frank Company-Run Stress Tests

On June 2, the Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve System and Office of the Comptroller of the Currency reiterated the disclosure requirements for annual stress tests conducted by financial institutions with total consolidated assets between $10 billion and $50 billion pursuant to the Dodd-Frank Act. The medium-sized firms are required to disclose certain information, including: a description of the types of risks included in the stress test; a summary description of the methodologies used in the stress test; estimates of losses, revenue, and net income; post-stress capital ratios; and an explanation of the most significant causes for the changes in regulatory capital ratios.  Joint Release.

SEC Provides Additional Analysis Related to Proposed Pay Ratio Disclosure Rules

On June 4, the Securities and Exchange Commission provided additional analysis related to its proposed rules for pay ratio disclosure.  The staff believes that the analysis will be informative for evaluating the potential effects on the accuracy of the pay ratio calculation of excluding different percentages of certain categories of employees, such as employees in foreign countries, part-time, seasonal, or temporary employees as suggested by commenters.  The staff is making the analysis available for public comment – comments may be submitted by July 6.  ReleaseAnalysis.

Rating Agency Developments

On June 1, DBRS released its RMBS Insight 1.2:  U.S. Residential Mortgage-Backed Securities Model and Rating MethodologyReport.

On June 1, Fitch released its U.S. RMBS Surveillance and Re-REMIC CriteriaReport.

On June 1, Moody’s issued RMBS Rating Methodology Supplement – IsraelReport.

On June 1, S&P issued Revised Assumptions For Rating U.S. RMBS Prime, Alternative-A, And Subprime Loans Incorporated Into LEVELS Version 7.4.3, effective immediately.  Report.

On June 1, S&P issued Revised U.S. Residential Mortgage Input File Format, Glossary, And Appendices To The Glossary For LEVELS Version 7.4.3, effective immediately.  Report.

On June 2, Fitch released its State Housing Finance Agencies:  MBS Pass-Through Bond Rating CriteriaReport.

On June 3, Fitch released its Criteria for Rating U.S. Timeshare Loan ABSReport.

On June 5, Fitch released its U.S. Nonprofit Institutions Rating CriteriaReport.

On June 5, S&P released its Global Container Lease-Backed ABS Methodology And AssumptionsReport.

Rating Agency Developments

On May 29, DBRS released its updated methodology for rating U.S. asset-backed commercial paperReport.

On May 29, Fitch republished its criteria for rating supranationalsReport.

On May 28, Fitch released its updated criteria for rating new-issue U.S. and Canadian multiborrower CMBSReport.

On May 28, Fitch released its updated criteria for rating solar power projectsReport.

On May 27, DBRS released its updated methodology for operational risk assessment of U.S. ABS servicersReport.

On May 27, Moody’s released its global methodology for rating reverse mortgage securitizationsReport.

On May 26, KBRA released its methodology for rating full-recourse secured aircraft-debt instruments issued by airlines and aircraft lessorsReport.

 

Federal Reserve Proposes Adding Additional Asset Types to Meet LCR Requirements

On May 21, the Federal Reserve Board proposed adding certain general obligation state and municipal bonds to the range of assets a banking organization may use to satisfy the Liquidity Coverage Ratio (LCR) requirements designed to ensure that large banking organizations have the capacity to meet their liquidity needs during a period of financial stress.  Subject to specified limits, the proposed rule would allow investment grade, general obligation U.S. state and municipal bonds to be counted as high-quality liquid assets (HQLA) up to certain levels if they meet the same liquidity criteria that currently apply to corporate debt securities.  ReleaseProposal.