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

Fannie Mae and Freddie Mac to Issue New Seller/Servicer Eligibility Requirements

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.  ReleaseFannie Mae and Freddie Mac FAQs.

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.  ReleaseUpdate.

Rating Agency Developments

On May 22, DBRS released its methodology for rating entities in the real estate industryReport.

On May 21, DBRS released its methodology for reviewing ratings of Canadian structured finance and covered bond transactionsReport.

On May 20, Moody’s released its methodology for rating trade receivables-backed transactionsReport.

On May 20, Moody’s released its methodology for rating “credit tenant lease” (CTL) obligationsReport.

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 ABSReport.

On May 18, Fitch updated its International Local and Regional Government Ratings CriteriaReport.

On May 18, Fitch updated its U.S. Public Power Rating CriteriaReport.

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 ReleaseFinal 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 ReleaseReport.

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 ReleaseStaff Letter.

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 transactionsReport.

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 transactionsReport.

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 counterpartyPress ReleaseNo-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 ReleaseNo-Action Relief.