Posts by: Eric Nyman

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

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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

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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

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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

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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

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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.