Posts by: Elizabeth Williams

Rating Agency Developments

 

On April 3, Moody’s published its Operating Company Securitizations. Methodology.

On April 3, KBRA published a report titled CMBS: Coronavirus (COVID-19): Multifamily Update – Bracing for Forbearance. Report.

On April 2, KBRA published a report titled Structured Credit: Coronavirus (COVID-19): KBRA U.S. BSL CLO Rating Sensitivity Analysis. Report.

On April 1, DBRS Morningstar published its U.S. Residential Mortgage-Backed Securities Model and Ratings. Methodology.

On March 31, DBRS Morningstar published its U.S. ABS General Ratings. Methodology.

Treasury Releases Guidance on Payroll Support and Loans Pursuant to CARES Act

 

On March 30, the U.S. Department of the Treasury published guidance related to the CARES Act. The guidelines and application procedures published focus on payroll support for air carriers and requirements for loans to air carriers and other eligible businesses under the CARES Act. Release.

Federal Agencies Make Joint Release Announcing Actions to Support Lending to Households and Businesses

 

On March 27, the Federal Reserve Board, the FDIC and the OCC announced two actions to support continued lending by banking organizations to households and businesses. The first action is early adoption of the standardized approach for measuring counterparty credit risks finalized in November 2019, with a new effective date of April 1, 2020. The second action is an interim final rule that allows banking organizations that would otherwise be required to adopt the new current expected credit loss accounting standard this year, to have the option of delaying adopting the new standard for up to two years. Federal Reserve Release. FDIC Release. OCC Release.

SEC Announces Temporary Relief and Assistance to Market Participants

 

On March 26, the SEC announced temporary measures to assist market participants in response to COVID-19. The actions include i) temporary relief from Form ID notarization requirements through July 1, ii) extended filing deadlines for certain reports and forms required under Regulation A and Regulation Crowdfunding issuers, and iii) a temporary exemption, subject to certain conditions, for required filings for municipal advisors through June 30. Release

CFTC Unanimously Passes Final Rule Affecting Formulation, Amendment or Repeal of Commission’s Rules and Regulations

 

On December 10, the U.S. Commodity Futures Trading Commission (CFTC) approved a final rule eliminating the provisions of the Commission’s Regulations that established the formulation, amendment or repeal of its rules or regulations. The CFTC unanimously passed the final rule, with rule makers stating these provisions were unnecessary because the CFTC’s rulemaking process is governed by the Administrative Procedure Act. Rule.

SEC Releases Guidance on Investment Advisers’ Proxy Voting Responsibilities

 

On August 21, the Securities and Exchange Commission (SEC) provided guidance for investment advisers in fulfilling their proxy voting responsibilities. The Commission also issued an interpretation that proxy voting advice provided by proxy advisory firms generally constitutes a “solicitation” under the federal proxy rules. Release.

Agencies Issue Joint Amendments to Regulation CC

 

On June 24, the Consumer Financial Protection Bureau and the Federal Reserve Board published joint amendments to Regulation CC. Regulation CC implements the Expedited Funds Availability Act of 1987, as amended by the Dodd-Frank Act. The joint amendments implement a statutory requirement to adjust for inflation the funds depository institutions are required to make available to their customers in certain circumstances. Release. Notice.