Posts by: Jill Pritzker

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.

Rating Agency Developments (May 8 – May 22)

 

On May 22, KBRA published a report titled Coronavirus (COVID-19): RMBS Forbearance and Delinquency Trends. Report.

On May 19, KBRA published a report titled Coronavirus (COVID-19): CARES Act Offers Lifeline to Transit Systems but Is No Panacea. Report.

On May 19, DBRS Morningstar published an updated ratings methodology titled Operational Risk Assessment for U.S. ABS Originators. Methodology.

On May 15, Moody’s published an updated ratings methodology titled Approach to Rating US and Canadian Conduit/Fusion CMBS. Methodology.

On May 15, Moody’s published an updated ratings methodology titled Moody’s Approach to Rating Securities Backed by FFELP Student Loans. Methodology.

On May 15, Moody’s published an updated ratings methodology titled Moody’s Global Approach to Rating Auto Loan- and Lease-Backed ABS. Methodology

On May 13, DBRS Morningstar published a new criteria article titled Rating U.S. Retail Auto Loan Securitizations. Methodology.

On May 13, DBRS Morningstar published a new criteria article titled Rating European Non-Performing Loans Securitizations. Methodology.

On May 13, Fitch published a new article titled Exposure Draft: Global Structured Finance Rating. Criteria.

On May 11, Fitch published a new criteria article titled U.S. RMBS Rating. Criteria.

On May 8, DBRS Morningstar published a new criteria article titled U.S. Reverse Mortgage Securitization Ratings. Methodology.

FDIC Issues Proposed Rule to Address Deposit Insurance Assessment Effect on Participation in the PPP, PPP Lending Facility and MMF Liquidity Facility

 

On May 12, the FDIC issued a proposed rule to mitigate the deposit insurance assessment effects of participating in the PPP and the PPP and Money Market Fund Liquidity Facilities. The proposed rule would remove certain FDIC assessment impacts on banks as a result of their participation in the PPP and the lending facilities. Release.

Rating Agency Developments

 

On March 31, KBRA published a report titled Coronavirus (COVID-19): Impact of Federal Stimulus on Securitizations Backed by Consumer Receivables. Report.

On March 30, KBRA assigned ratings for the Carvana Auto Receivables Trust 2020-N1 transaction. Release.

On March 30, KBRA assigned ratings for the CSAIL 2020-C19 transaction. Release.

On March 24, KBRA assigned ratings to the BMARK 2020-B17 transaction. Release.

On March 20, DBRS Morningstar published its Global Structured Finance Related Methodologies criteria. Methodology.

On March 19, KBRA assigned ratings to the Progress Residential 2020-SFR1 transaction. Release.

On March 19, KBRA published a new issue report for the Sequoia Mortgage Trust 2020-3 transaction. Report.

On March 19, KBRA published a new issue report for the First Investors Auto Owner Trust 2020-1 transaction. Report.

On March 19, DBRS Morningstar published its U.S. ABS General Ratings Methodology criteria. Methodology.

On March 18, Fitch published its U.S. Auto Loan ABS Rating. Criteria.

On March 18, Fitch published its U.S. Auto Lease ABS Rating. Criteria.

On March 18, DBRS Morningstar published its Rating Canadian ABCP and Related Enhancement Features. Methodology.

On March 13, DBRS Morningstar published its European RMBS Insight: Greek Addendum. Methodology.

On March 13, DBRS Morningstar published its European RMBS Insight: Dutch Addendum. Methodology.

On March 12, Fitch published its RMBS Lenders’ Mortgage Insurance Rating. Criteria.

FHFA Suspends Foreclosures and Evictions for Enterprise-Backed Mortgages

 

On March 18, the Federal Housing Finance Agency (FHFA) and the U.S. Department of Housing and Urban Development (HUD) made a joint announcement to suspend all foreclosures and evictions for homeowners with mortgages backed by Freddie Mac and Fannie Mae for 60 days. The moratorium on evictions and foreclosures aim to provide relief for borrowers impacted by the coronavirus pandemic. FHFA Release. HUD Release. CFPB Release.

Joint Agency Statement Issued Regarding Residential Mortgage Loan Modifications and Troubled Debt Restructuring

 

On March 22, the Board of Governors of the FRB, FDIC, the National Credit Union Administration, OCC, CFPB and the State Banking Regulators issued an interagency statement encouraging financial institution cooperation with borrowers during the COVID-19 pandemic. The statement provided guidance on the troubled debt restructurings and related accounting requirements. Release.

Federal Reserve Announces New Efforts to Stabilize U.S. Economy

 

On March 23, the Federal Reserve announced several new measures it will take in an effort to support and stimulate the economy during the COVID-19 pandemic. The Federal Open Market Committee will purchase Treasury securities and agency mortgage-backed securities (including commercial mortgage-backed securities). Several new credit facilities will be established to support the flow of credit – the Primary Market Corporate Credit Facility (PMCCF), the Secondary Corporate Credit Facility (SMCCF) and the Term Asset-Backed Securities Loan Facility (TALF). Certain existing credit facilities will be expanded to include additional securities – the Money Market Mutual Fund Liquidity Facility (MMLF) and the Commercial Paper Funding Facility (CPFF). The Federal Reserve also announced plans to create a Main Street Business Lending Program to facilitate lending to small businesses. Release.

SEC Announces Relief for Public Company Disclosure Report Filing Deadlines and Filing and Meeting Requirements under Investment Advisers Act

 

On March 25, the SEC announced a 45-day filing extension for certain public company disclosure reports due between March 1 and July 1. The SEC also announced certain filing and delivery requirement exemptions under the Investment Advisers Act of 1940 as well as additional time to hold in-person board meetings. Release.