Jill Pritzker

Managing Associate

New York


Read full biography at www.orrick.com

Jill Pritzker, a Managing Associate in the Structured Finance group, represents a variety of market participants, including issuers, underwriters and service provides, in public and private offerings of commercial mortgage-backed securities. Jill also maintains an active pro bono practice, including representing non-profit organizations on corporate formation matters.

 

 

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Posts by: Jill Pritzker

SEC Proposes Amendment to Rule 144

 

On December 22, the SEC proposed to amend Rule 144. Among other things, the amendment would revise the holding period determination to the date of acquisition upon the conversion or exchange for market-adjustable securities acquired on the conversion or exchange of certain securities of issuers that do not have securities listed on a national securities exchange. The amendment would also require electronic filing of Form 144 and would eliminate the requirement to file Form 144 for resales of securities of issuers that are not subject to Exchange Act reporting. The public comment period will be open for 60 days following the publication of the proposed rule in the Federal Register. Release.

FHFA Extends COVID-19 Multifamily Mortgage Forbearance through March 31, 2021

 

On December 23, the Federal Housing Finance Authority (FHFA) announced an extension of the COVID-19 relief mortgage forbearance to qualifying multifamily property owners through March 31, 2020, which was previously set to expire on December 31, 2020. The relief program also extends certain protections to related tenants. Release.

SEC Adopted a New Rule Allowing Registered Funds to Enter Into Derivative Transactions

 

On October 28, the Securities and Exchange Commission (SEC) adopted a new rule 18f-4 under the Investment Company Act of 1940 allowing registered funds to enter into derivative transactions, provided they comply with certain conditions intended to protect investors. The rule will become effective 60 days after publication with an 18-month transition period for compliance with the provisions and related reporting requirements. Release.

OCC Submitted Final Rule Clarifying When Bank is a “True Lender”

 

On October 27, the Office of the Comptroller of the Currency (OCC) submitted a final rule for publication to determine when a national bank or federal savings association makes a loan to a third party and is the “true lender.” The rule clarifies that a bank is a “true lender” if, as of the date of origination, the bank (1) is named as the lender in the loan agreement or (2) funds the loan. OCC Bulletin.

New York Fed Released Revised Master Loan and Security Agreement for TALF

 

On October 22, the Federal Reserve Bank of New York released a revised Master Loan and Security Agreement (MLSA) related to the use of the Term Asset-Backed Securities Loan Facility (TALF). The changes to the MLSA will be effective as of November 5. Release.

Treasury and IRS Issue Guidance on Deferred Payroll Taxes

 

On August 28, the U.S. Treasury Department and the IRS issued guidance to employers regarding the executive action taken earlier this month to defer certain employee payroll taxes through the end of the year. The guidance allows employers to defer payment through the end of 2020 of the employee’s portion of Social Security payroll tax for employee’s earning monthly pre-tax wages of $4,000 or less. Release.

Rating Agency Developments (August 24 – September 1)

 

On September 1, KBRA published its Structured Finance: CMBS report titled Coronavirus (COVID-19): Affiliate of On-Demand Office Provider Regus Files for Bankruptcy—CMBS Exposure Examined. Report.

On September 1, DBRS Morningstar published its methodology titled DBRS Morningstar Global Structured Finance Related Methodologies. Methodology.

On August 28, DBRS Morningstar published its methodology titled U.S. Residential Mortgage Servicer Rankings. Methodology.

On August 28, DBRS Morningstar published its methodology titled U.S. Residential Mortgage Originator Rankings. Methodology.

On August 28, KBRA published its report titled CMBS/RMBS: Single-Borrower SFR Comprehensive Surveillance. Report.

On August 27, KBRA published its rating methodology titled ABS: Global Auto Loan ABS Rating. Methodology.

On August 24, KBRA published its research report titled Structured Credit: Coronavirus (COVID-19): U.S. BSL CLO Sector Exposure Map: July 2020. Report.

CFPB Issues Report on Impacts of COVID-19 on Consumer Credit

 

On August 31, the Consumer Financial Protection Bureau (CFPB) issued a report examining the early impact of the COVID-19 pandemic on consumer credit. The report noted no significant negative impact on consumer credit or delinquencies, focusing on mortgage, auto loans, credit cards and student loans, from March 2020 to June 2020, suggesting programs such as the CARES Act may have positively impacted consumer credit during this time. Report.

SEC Adopts Rule Amendments to Applications for Exemption Under the Investment Company Act

 

On July 6, the Securities and Exchange Commission (SEC) announced that it had voted to adopt rule amendments to establish an expedited review process for applications for exemption for funds under the Investment Company Act. The new process is intended to make the process of applying for more routine exemptions quicker and less expensive for applicants. Release.

Rating Agency Developments (July 2 – July 15)

 

On July 15, Fitch published an article titled Originator-Specific Residential Mortgage Analysis Rating. Criteria.

On July 14, Fitch published an article titled U.S. Public Finance Prepaid Energy Transaction Rating. Criteria.

On July 13, KBRA published a report titled Public Finance: Coronavirus (COVID-19): Why Does Federalism Matter to Municipal Credit? Report.

On July 10, Moody’s published an updated ratings methodology titled Short-term Debt of U.S. States, Municipalities and Nonprofits. Methodology.

On July 10, Fitch published an updated ratings methodology titled Public-Sector Counterparty Obligations in PPP Transactions Rating. Criteria.

On July 10, Fitch published an article titled U.S. RMBS Coronavirus-Related Analytical Assumptions. Criteria.

On July 10, KBRA published a report titled Financial Institutions: U.S. Banks: Thinking Through the Great Unknown-Loan Losses in the Pandemic. Report.

On July 8, Moody’s published a methodology titled Moody’s Approach to Rating Asset-Backed Commercial Paper. Methodology.

On July 7, Moody’s published a methodology titled U.S. RMBS Surveillance. Methodology.

 On July 7, DBRS Morningstar published a methodology titled Rating U.S. Equipment Lease and Loan Securitizations. Methodology.

On July 6, Moody’s published a methodology titled Moody’s Global Approach to Rating Securities Backed by Aircraft and Associated Leases. Methodology.

On July 2, Moody’s published a methodology titled Single-Family Rental Securitizations. Methodology.