On May 20, the FHFA announced that Fannie Mae and Freddie Mac are issuing new finalized operational and financial eligibility requirements for mortgage seller/servicers. The updated requirements will be communicated through guides, bulletins and announcements and through best practices documents provided by Fannie and Freddie. The operational requirements become effective no later than September 1, 2015 and the financial requirements become effective December 31, 2015. Release. Fannie Mae and Freddie Mac FAQs.
S. Chris Min, a partner in the New York office, is a member of the Structured Finance Group. Chris represents issuers, sponsors, underwriters, and other market participants in connection with public offerings and private placements of various asset-backed securities as well as other types of asset financing and sales.
Chris has broad experience with several asset classes, including credit card and charge card receivables, auto loans and leases, dealer floorplan loans, consumer loans, small business loans, and municipal bonds. Chris also regularly advises financial institutions on the application of securities laws and other regulations affecting the financial industry.
Posts by: Chris Min
FHFA Releases Update on the Single Security Project
On May 15, the FHFA released an update on the structure of the Single Security, a project involving the development of a single mortgage-backed security that would be issued by Fannie Mae or Freddie Mac. The update contains FHFA’s decisions made in response to input previously provided by industry stakeholders. Release. Update.
Rating Agency Developments
On May 22, DBRS released its methodology for rating entities in the real estate industry. Report.
On May 21, DBRS released its methodology for reviewing ratings of Canadian structured finance and covered bond transactions. Report.
On May 20, Moody’s released its methodology for rating trade receivables-backed transactions. Report.
On May 20, Moody’s released its methodology for rating “credit tenant lease” (CTL) obligations. Report.
On May 20, Moody’s released its methodology for rating corporate synthetic collateralized debt obligations (CSOs). Report.
On May 19, Moody’s released its methodology for rating commercial mortgage backed securities (CMBS) in Europe, Middle East and Africa (EMEA). Report.
On May 19, Fitch released its updated criteria for rating global aircraft operating lease ABS. Report.
On May 18, Fitch updated its International Local and Regional Government Ratings Criteria. Report.
On May 18, Fitch updated its U.S. Public Power Rating Criteria. Report.
Agencies Issue Final Rule Implementing Minimum Requirements for Appraisal Management Companies
On April 30, six federal regulatory agencies jointly issued a final rule establishing minimum requirements for state registration and supervision of appraisal management companies that provide appraisal management services to lenders, underwriters and other principals in the secondary mortgage markets, as required by Section 1473 of the Dodd-Frank Act. Press Release. Final Rule.
FHFA Release Results of Fannie Mae and Freddie Mac Dodd-Frank Stress Tests
On April 30, the Federal Housing Finance Agency (FHFA) released a report providing the results of annual stress tests Fannie Mae and Freddie Mac are required to undergo under the Dodd-Frank Act. The report provide updated information on possible ranges of future financial results for Fannie Mae and Freddie Mac under severely adverse economic conditions. Press Release. Report.
CFTC Issues Interpretive Letter Clarifying Eligibility for End-User Exception to the Clearing Requirement
On May 4, CFTC Division of Clearing and Risk published a letter clarifying that a securitization SPV that is wholly-owned by, and consolidated with, a captive finance company under Section 2(h)(7)(C)(iii) of the Commodity Exchange Act (CEA) is also eligible for the end-user exception to a clearing requirement under Section 2(h)(1)(A) of the CEA. Press Release. Staff Letter.
Rating Agency Developments
Rating Agency Developments
On March 27, DBRS released its updated methodology for rating North American commercial mortgage-backed securities (CMBS). Report.
On March 27, Fitch released its updated criteria for analyzing U.S. wireless tower transactions. Report.
On March 31, Fitch released its updated criteria for analyzing loans securing residential mortgage-backed securities (RMBS) under the ability-to-repay and qualified mortgage standards that the Bureau of Consumer Financial Protection adopted as part of its amendments to Regulation Z under the Truth in Lending Act. Report.
On April 1, DBRS released its updated methodology for the surveillance of European structured finance and covered bonds transactions. Report.
CFTC Staff Issues No-Action Relief for Swaps with Legacy SPVs
On March 31, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to provisionally registered swap dealers (SDs) from complying with certain specified regulations when entering into swaps with legacy SPVs. Subject to certain specified conditions, the relief is provided for swaps that are entered into with legacy SPVs in replacement of existing swaps executed on or prior to October 10, 2013, solely for purposes of addressing a reasonably anticipated credit downgrade of an SD counterparty. Press Release. No-Action Relief.
CFTC Staff Issues No-Action Relief Regarding CCO Annual Report Timing Requirement
On March 27, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to futures commission merchants, swap dealers and major swap participants from their obligation under Regulation 3.3(f)(2) to provide annual reports by their Chief Compliance Officers not more than 60 days after the end of their fiscal year. The no-action letter grants an additional 30 days to provide the annual reports to the CFTC. Press Release. No-Action Relief.