Michael H. Sugarman

Associate

Los Angeles


Read full biography at www.orrick.com

Michael H. Sugarman is a lawyer in Orrick's Structured Finance Group, based in the Los Angeles office. Michael specializes in structured finance and has extensive experience advising on procedural rules and substantive policies in federal matters.

During law school, Michael served as a judicial extern for the Honorable George H. Wu of the United States District Court, Central District of California. Michael also served as Executive Editor of the Loyola of Los Angeles International and Comparative Law Review.  Prior to joining Orrick, Michael served as a law clerk to multiple magistrate judges in the United States District Court, Central District of California and worked as an associate for the Law Offices of Steven Goldsobel, A Professional Corporation.

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Posts by: Michael Sugarman

FHFA Requests Input on FHFA’s Draft Strategic Plan for Fiscal Years 2018-2022

 

On September 27, 2017, the Federal Housing Finance Agency requested comment on its proposed strategic plan, which “…reflects the Agency’s priorities as regulator of the Federal Home Loan Bank System and as regulator and conservator of Fannie Mae and Freddie Mac[.]” Release.

FDIC Adopts Final Rule on Qualified Financial Contracts

 

On September 27, 2017, the Federal Deposit Insurance Corporation finalized a rule, similar to the rule approved by the Federal Reserve Board, relating to termination and cancellation rights for specified contracts and specified institutions. Applicable types of agreements include “derivatives, securities lending, and short-term funding transactions, such as repurchase agreements.” FDIC Release.

Agencies Propose Simplifying Regulatory Capital Rules

 

On September 27, 2017, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the Office of the Comptroller of the Currency announced a proposed rule intended to decrease regulation under these entities’ “regulatory capital rule.” The proposed rule “would apply only to banking organizations that are not subject to the ‘advanced approaches’ in the capital rule, which are generally firms with less than $250 billion in total consolidated assets and less than $10 billion in total foreign exposure.” FDIC Release. Federal Reserve Release. OCC Release.

CFTC’s Division of Market Oversight Extends Existing Relief and Provides Additional Relief for Reporting Parties From Reporting Obligations as Required by the OCR Final Rule

 

On September 25, 2017, the Division of Market Oversight of the U.S. Commodity Futures Trading Commission “issued a no-action letter (CFTC Staff Letter 17-45) that extends current relief and provides additional relief to reporting parties from [certain] reporting obligations[ under a 2013 final rule relating to ownership and control in futures and swap markets.]” Release.

Community Reinvestment Act Regulations: Notice of Proposed Rulemaking

 

On September 22, 2017, multiple government agencies announced “… a proposed rule that would revise their regulations implementing the Community Reinvestment Act (CRA) (12 USC 2901 et seq.). The proposed rule would amend the CRA regulations’ definitions of ‘home mortgage loan’ and ‘consumer loan’ to conform to recent changes made by the Consumer Financial Protection Bureau to Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The proposed rule would also amend the CRA public file content requirements for consistency with Regulation C, make technical amendments to remove cross references related to the proposed amended definitions, and remove an obsolete reference to the Neighborhood Stabilization Program.” Release.

Agencies to Propose Amending CRA Regulations to Conform to HMDA Regulation Changes, and Remove References to the Neighborhood Stabilization Program

 

On September 13, 2017, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly released proposed changes to each agency’s Community Reinvestment Act’s regulations relating “Regulation C, which implements the Home Mortgage Disclosure Act[.]” FDIC Release. Federal Reserve Release. OCC Release.

Rating Agency Developments

 

On September 13, 2017, DBRS issued a report entitled Third-Party Due Diligence Criteria for U.S. RMBS Transactions. Report.

On September 13, 2017, Fitch issued a report entitled Fitch Updates Future Flow Securitisation Criteria; No Rating Impact. Release.

On September 11, 2017, KBRA issued a report entitled Financial Institutions: Global Asset Manager Rating Methodology. Report.

On September 11, 2017, KBRA issued a report entitled Public Finance: U.S. Third Party Liquidity Facility-Supported Variable Rate Demand Obligations and Commercial Paper Rating Methodology. Report.

On September 11, 2017, KBRA issued a report entitled Corporates: General Corporate Rating Methodology. Report.

On September 7, 2017, Fitch issued a report entitled Fitch: LIBOR Transition Creates Uncertainty for SF Market. Release.