Posts by: Editorial Team

Agencies Extend Comment Period for Advance Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

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On January 13, 2017, the Federal Reserve Board, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation changed, from January 17, 2017 to February 17, 2017, the deadline for comments “for the advance notice of proposed rulemaking on enhanced cyber risk management standards for large and interconnected entities under their supervision and those entities’ service providers.” Cyber standards are being contemplated in five areas: “cyber risk governance; cyber risk management; internal dependency management; external dependency management; and incident response, cyber resilience, and situational awareness.” Federal Reserve Release. OCC Release. FDIC Release.

CFTC Unanimously Approves Proposal to Amend Recordkeeping Requirements

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On January 12, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) “approved proposed amendments to Regulation 1.31 … [that] … would modernize and make technology‑neutral the form and manner in which regulatory records must be kept, as well as rationalize the rule text for ease of understanding.” The CFTC is accepting comments on the proposed amendments until 60 days after the Federal Register publishes the proposed amendments. Release.

Rating Agency Developments

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On November 16, 2016, Fitch issued a report entitled: Fitch Updates Recovery Ratings and Notching Criteria for Equity REITs. Release.

On November 16, 2016, Fitch issued a report entitled: Fitch Updates Rating Criteria for U.S. Military Housing. Release.

On November 15, 2016, Fitch issued a report entitled: Fitch Updates U.S. RMBS Surveillance and Re‑REMIC Criteria. Release.

On November 11, 2016, Fitch issued a report entitled: Fitch Updates U.S. and Canadian Multiborrower CMBS Surveillance Criteria. Release.

On November 11, 2016, Moody’s updated its Index of Rating Methodologies. Report.

On November 11, 2016, Moody’s updated its index entitled: Outdated Credit Rating Methodologies. Report.

On November 10, 2016, Fitch issued a report entitled: Fitch Updates Surveillance Criteria for U.S. CREL CDOs. Release.

On November 10, 2016, Fitch issued a report entitled: Fitch Clarifies Criteria for Rating U.S. FFELP Student Loan ABS. Release.

On November 10, 2016, Moody’s issued a report entitled: U.S. Housing Finance Agency Single Family Programs. Report.

On November 10, 2016, Moody’s issued a report entitled: U.S. Housing Finance Agency Multifamily Methodology. Report.

On November 10, 2016, Moody’s issued a report entitled: U.S. Public Housing Authority Capital Fund Bonds. Report.

On November 10, 2016, Moody’s issued a report entitled: U.S. Housing Finance Agency Issuer Rating Methodology. Report.

On November 10, 2016, Moody’s issued a report entitled: Refining and Marketing Industry. Report.

CFTC Division of Market Oversight Reminds Market Participants of the Upcoming Expiration of Certain No Action Relief From the Ownership and Control Final Rule

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On November 16, 2016, the U.S. Commodity Futures Trading Commission (the “CFTC“) issued a reminder that previously specified no‑action relief will shortly be expiring. On November 18, 2016, at 12:00 a.m. Eastern time, revised electronic submission requirements for Forms 40/40S and 71 were put in effect. Release.

CFTC Approves Final Rule Amending the Timing for Filing Chief Compliance Officer Annual Reports by Certain Registrants

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On November 10, 2016, the U.S. Commodity Futures Trading Commission (the “CFTC“) issued a final rule modifying and clarifying previous guidance regarding compliance reports for futures commission merchants, swap dealers and major swap participants. Release.

Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

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On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency announced proposed rules relating to cybersecurity and risk management concerns that would apply to larger institutions under their purview. FDIC Press Release. Federal Reserve Press Release. OCC Press Release.

Rating Agency Developments

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On October 17, 2016, DBRS issued a report entitled: CMBS North American Surveillance. Report.

On October 14, 2016, Moody’s issued a report entitled: Moody’s Approach to Rating Securities Backed by Pools of Both FFELP and Private Student Loans. Report.

On October 14, 2016, DBRS issued a report entitled: Global Methodology for Rating Finance Companies. Report.

Commission Approves an Order Regarding Swap Dealer Registration De Minimis Exception

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On October 13, 2016, the U.S. Commodity Futures Trading Commission extended until December 31, 2018, the $8 billion swap dealer registration de minimis threshold. Unless it is further modified, the threshold will become $3 billion once the extension expires. Press Release.