Jill Pritzker

Managing Associate

New York


Read full biography at www.orrick.com

Jill Pritzker, an associate in the New York office, is a member of the Structured Finance Group.

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Posts by: Jill Pritzker

SEC Proposes to Modernize Disclosures of Business, Legal Proceedings and Risk Factors Under Regulation S-K

 

On August 8, the SEC announced that it has voted to propose rule amendments to modernize and simplify certain disclosures required pursuant to Regulation S-K since the regulation was first adopted over 30 years ago. The proposal addresses Items 101(a) (description of the general development of the business), 101(c) (the narrative description of the business) and 105 (risk factors). The proposal has a 60-day public comment period following the proposal’s publication in the Federal Register. Release. Proposal.

Rating Agency Developments

 

On April 9, Fitch published a report entitled: “U.S. Credit Card ABS Performance Mixed.” Report.

On April 8, Fitch published a report entitled: “U.S. CMBS Delinquency Rate Posts Increase in March.” Report.

On April 4, S&P published criteria and guidance reports entitled: “Structured Finance – ABS: U.S. FFELP Student Loan ABS: Methodology and Assumptions.” Criteria. Report.

Federal Reserve Board Releases Scenarios for 2019 Stress Test Exercises

 

On February 5, the Federal Reserve Board and Office of Comptroller of Currency released the stress scenarios for the 2019 stress test cycle for domestic bank holding companies and foreign bank intermediate bank holding companies with more than $100 billion in total consolidated assets. Banks are required to submit the results of their stress tests to the Federal Reserve by April 5, and the Federal Reserve will release results of its supervisory stress tests by June 30. The Federal Reserve Board announced that banks with consolidated assets between $100 and $250 billion will be relieved from the 2019 cycle. Release.