Eric Nyman


Los Angeles

Read full biography at
Eric Nyman, an associate in Orrick's Los Angeles office, is a member of the firm's Structured Finance Group.

Eric earned his J.D. and a certificate in Business Law from the University of Southern California Gould School of Law. While in law school, Eric was a legal intern for the Enforcement Division of the Securities and Exchange Commission.  Eric also served as research assistant to USC tax law Professor Edward McCaffery.  

Posts by: Eric Nyman

Rating Agency Developments (May 22 – June 3)


On June 3, KBRA published a Structured Finance research report titled CMBS: Coronavirus (COVID-19): CMBS Loan Performance Trend Update. Report

On June 3, KBRA published a report titled Public Finance: Coronavirus (COVID-19): States Brace for Unprecedented Medicaid Expansion. Report.

On June 2, KBRA published a report titled ABS: Coronavirus (COVID-19): Modifying Auto and Consumer Loan Delinquency Expectations. Report

On May 29, KRBA published a Structured Finance – CMBS surveillance report titled CMBS: BANK 2019-BNK18. Report.

On May 27, Fitch published an updated rating methodology titled APAC Residential Mortgage Rating Criteria. Methodology.

On May 27, DBRS Morningstar published its updated methodology titled U.S. ABS Surveillance. Methodology.

On May 22, Moody’s published an updated rating methodology titled Moody’s Approach to Rating Large Loan and Single Asset/Single Borrower CMBS. Methodology.

On May 22, Moody’s published an updated rating methodology titled Moody’s Approach to Rating Derivative Product Companies. Methodology.

FHFA Publishes Final Rule on the FHLBanks’ Housing Goals


On June 3, the Federal Housing Finance Agency (FHFA) sent for publication a final rule on the Federal Home Loan Banks’ Housing Goals, which eliminates the retrospective evaluation using HMDA data and set a single prospective mortgage purchase housing goal as a share of each FHLBank’s total Acquired Member Asset purchases. The rule also sets a new small member participation housing goal for participation by small institutions, eliminates the volume threshold and simplifies the eligibility criteria to enable federally backed loans sold by small institutions eligible to count for goals purposes. Release.

Federal Reserve Board Announces Expansion in the Number and Type of Entities Eligible to Directly Use Its Municipal Liquidity Facility


On June 3, the Federal Reserve Board announced an expansion in the number and type of entities eligible to directly use its Municipal Liquidity Facility (MLF). Under the new terms, all U.S. states will be able to have at least two cities or counties eligible to directly issue notes to the MLF, regardless of population. Governors of each state will also be able to designate two issuers in their jurisdictions whose revenues are generally derived from operating government activities to be eligible to directly use the facility. Release.

CFTC: Interim Final Rule – Uncleared Swaps Margin – Proposed Rule: CPO Registration Exemption


On May 28, the Commodity Futures Trading Commission (CFTC) approved an interim rule to grant an extension of the compliance schedule for initial margin requirements for uncleared swaps in response to operational challenges certain entities are facing due to the COVID-19 pandemic. The CFTC also approved a proposed rule that amends regulation 3.10(c)(3), which provides an exemption from registration as a CPO for certain persons located outside the U.S. who are operating offshore commodity pools that are neither offered nor sold to U.S. participants. Release.

Rating Agency Developments


On March 18, KBRA published its Coronavirus (COVID-19): Consumer ABS Braces for Disruptions. Report.

On March 13, KBRA published its General Global Rating for Asset-Backed Securities. Methodology.

On March 13, KBRA published its Aviation ABS Global Rating. Methodology.

On March 13, KBRA published its Equipment Lease & Loan Global ABS Rating. Methodology.

On March 13, KBRA published its Project Finance Global Rating. Methodology.

On March 13, KBRA published its Structured Credit Global Rating. Methodology.

On March 12, KBRA published its Financial Guaranty Global Rating. Methodology.

On March 11, DBRS Morningstar published a report entitled: Mapping Financial Institution Internal Ratings to DBRS Morningstar Ratings for Global Structured Credit Transactions. Methodology.

On March 10, Fitch published its rating for Aircraft Operating Lease ABS. Criteria.

On March 9, DBRS Morningstar published its North American CMBS Multi-Borrower Rating. Methodology.

On March 9, Moody’s published its proposed update for rating TruPS CDOs. Methodology.

On March 6, DBRS Morningstar published its North American CMBS Surveillance. Methodology.

On February 19, DBRS Morningstar published its U.S. Federal Family Education Loan Program Securitizations. Criteria.

On February 18, Fitch published its U.S. Public Finance Letter of Credit-Supported Bonds and Commercial Paper Rating. Criteria.

Fannie Mae and Freddie Mac Publish Joint Enterprise Credit Score Solicitation


On February 18, the Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac (the “Enterprises”) have published a Joint Credit Score Solicitation, which describes the process for credit score model developers to submit applications to the Enterprises. The publication of the solicitation in the process of evaluating new credit score models will ensure that the Enterprises validate and approve credit score models in a timely and prudent manner. Release.

Federal Deposit Insurance Corporation Releases Economic Scenarios for 2020 Stress Testing


On February 14, the Federal Deposit Insurance Corporation (FDIC) released the hypothetical economic scenarios for use in the upcoming stress tests for covered institutions with total consolidated assets of more than $250 billion. Required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the economic stress test scenarios include 28 variables – such as gross domestic product, the unemployment rate, stock market prices, and interest rates – covering domestic and international activity designed to assess the strength and resilience of financial institutions. Release.

Securities and Exchange Commission Proposes to Modernize Key Market Infrastructure Responsible for Collecting, Consolidating, and Disseminating Securities Market Data


On February 14, the SEC proposed to modernize the infrastructure for the collection, consolidation, and dissemination of market data for exchange-listed national market system (NMS) stocks. Comments on the proposed SEC Rule are due 60 days after publication in the Federal Register. Release.