Posts by: Editorial Team

Community Reinvestment Act Regulations: Notice of Proposed Rulemaking

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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

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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

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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.

SEC Issues Investigative Report Concluding DAO Tokens, a Digital Asset, Were Securities

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On July 25, 2017, the Securities and Exchange Commission (the “SEC“) released a report indicating that many offerings of “digital assets[,]” such as those using “distributed ledger or blockchain technology,” could be subject to federal securities laws. In this specific instance, the SEC chose not to bring charges or find violations but to go further into the SEC’s positions on this emerging sector. Press Release.

CFTC Staff Extends Time-Limited No-Action Relief on the Applicability of Transaction-Level Requirements in Certain Cross-Border Situations

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On July 25, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) “issued a time-limited no-action letter that extends relief to swap dealers [] registered with the CFTC that are established under the laws of jurisdictions other than the United States [] from certain transaction-level requirements under the Commodity Exchange Act.” Press Release.

Federal Reserve Board Announces Guidelines for Banking Entities Seeking an Extension to Conform Certain “Seeding” Investments in Hedge Funds or Private Equity Funds to Requirements of Volcker Rule

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On July 24, 2017, the Federal Reserve Board “announced guidelines for banking entities seeking an extension to conform certain ‘seeding’ investments in hedge funds or private equity funds (‘covered funds‘) to the requirements of … the Volcker Rule.” In part, the new guidelines require further detail regarding “the reasons for the extension and an explanation of the entity’s plan to conform the investment to the requirements of” the Volcker Rule. Press Release.

Federal Regulatory Agencies Announce Coordination of Reviews for Certain Foreign Funds Under “Volcker Rule”

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On July 21, 2017, the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, the Office of Comptroller of the Currency and the Securities and Exchange Commission announced they would work together as they reviewed the impact of the Volcker Rule on specific types of foreign funds. Federal Reserve Press Release. FDIC Press Release. OCC Press Release. SEC Press Release.

Rating Agency Developments

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On July 26, 2017, Moody’s issued the following reports:

On July 21, 2017, Fitch issued a report entitled Fitch Revises Sovereign Rating Criteria. Report.

On July 21, 2017, Fitch issued a report entitled Fitch Updates Country Ceilings Criteria. Report.

On July 20, 2017, Fitch issued a report entitled Fitch Updates Availability-Based Projects Rating Criteria. Report.