Paolo R. Olavario

Associate

New York


Read full biography at www.orrick.com

Paolo R. Olavario is an associate in Orrick's New York Office and practices in the Structured Finance group. 

Paolo represents issuers, underwriters, loan sellers and loan purchasers in public and private securitizations, with a particular focus on commercial mortgage-backed securities. He has worked on conduit programs and single asset / single borrower transactions. He also has experience representing underwriters in connection with residential mortgage-backed securities offerings and asset-backed securities offerings, including auto loans.  

Posts by: Paolo Olavario

Rating Agency Developments

 

On April 27, KBRA published a report titled Public Finance: Coronavirus (COVID-19): Municipal Issuers’ Virus-Related Voluntary Disclosures Trend Up. Report.

On April 21, Moody’s published its revised approach to rating U.S. RMBS using the MILAN Framework. Methodology.

On April 20, KBRA published a report titled Public Finance: Coronavirus (COVID-19): Sales Tax Bonds Under Surveillance. Report.

On April 17, S&P published its revised methodology and assumptions for rating U.S. RMBS issued in 2009 or later. Methodology.

On April 16, KBRA published a report titled CMBS: Coronavirus (COVID-19): CRE Recovery Clues From the Great Recession and China. Report.

On April 15, KBRA published a report titled Public Finance: Coronavirus (COVID-19): Fed Provides Vital Assistance to State and Local Governments. Report.

On April 15, Fitch published an article titled Exposure Draft: U.S. RMBS Coronavirus-Related Analytical Assumptions. Criteria.

On April 15, DBRS Morningstar published its methodology for Currency Stresses for Global Structured Finance Transactions. Methodology.

On April 14, Moody’s published its methodology for Fleet Lease Securitizations. Methodology.

On April 13, DBRS Morningstar published its methodology for Rating Structured Aircraft Transactions. Methodology.

On April 10, Moody’s published its methodology for Reverse Mortgage Securitizations. Methodology.

On April 10, Moody’s published its methodology for Resecuritizations. Methodology.

On April 10, Fitch published its criteria for CMBS Large Loan Rating. Criteria.

Interim Final Rule and Interagency Statement for Real Estate-Related Financial Transactions Affected by the Coronavirus

 

On April 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) today announced an interim final rule that allows financial institutions to defer completion of appraisals and evaluations after the closing of certain residential and commercial real estate transactions. The deferrals provide flexibility for completing appraisals and evaluations to help financial institutions meet the immediate liquidity needs of borrowers during the coronavirus emergency. The interim final rule authorizes deferrals of appraisals and evaluations for all residential and commercial real estate transactions, except for transactions involving the acquisition, development, and construction of real estate, allows a bank up to 120 days from the closing of a transaction to obtain the appraisal or evaluation required under the appraisal regulations, and authorizes deferrals until December 31, 2020, when the interim final rule terminates. Bulletin.

Federal Bank Regulators Issue Interim Final Rule for Paycheck Protection Program Facility

 

On April 9, the federal bank regulatory agencies today announced an interim final rule to encourage lending to small businesses through the Small Business Administration’s Paycheck Protection Program (PPP). The interim final rule modifies the agencies’ capital rules to neutralize the regulatory capital effects of participating in the Federal Reserve’s PPP facility because there is no credit or market risk in association with PPP loans pledged to the facility. Consistent with the agencies’ current capital rules and the CARES Act requirements, the interim final rule also clarifies that a zero percent risk weight applies to loans covered by the PPP for capital purposes. The rule is effective immediately. Release.

Treasury and Federal Reserve Board Announce Main Street Business Lending Program and a Municipal Liquidity Facility

 

On April 9, the Treasury and Federal Reserve Board announced the establishment of the Main Street Business Lending Program and a Municipal Liquidity Facility. The Main Street Business Lending Program will enable up to $600 billion in new financing for businesses with up to 10,000 employees or $2.5 billion in 2019 annual revenues. The Municipal Liquidity Facility will provide up to $500 billion in direct financing to states, counties and cities. States, counties and cities will be able to sell new municipal notes directly to the Municipal Liquidity Facility to obtain the funds they need. Release.

FRB Finalizes Rules that Tailor its Regulations for Banks to More Closely Match Their Risk Profiles

 

On October 10, the Federal Reserve Board (FRB) finalized rules that tailor its regulations for domestic and foreign banks to more closely match their risk profiles. The rules establish a framework that sorts banks with $100 billion or more in total assets into four different categories based on several factors, including asset size, cross-jurisdictional activity, reliance on short-term wholesale funding, nonbank assets, and off-balance sheet exposure. Firms in the lowest risk category will have reduced compliance requirements, and as the risk of a firm increases and it moves into a new risk category, its requirements will increase. Release.

Thresholds Increase for the Major Assets Prohibition of the Depository Institution Management Interlocks Act Rules

 

On October 10, the Office of the Comptroller of the Currency (OCC) published a final rule in the Federal Register that increases the major assets prohibition thresholds for management interlocks in the OCC’s rule implementing the Depository Institution Management Interlocks Act (DIMIA). The final rule reduces the number of national banks and federal savings associations subject to the major assets prohibition in the OCC’s DIMIA rule by increasing both major assets prohibition thresholds from $1.5 billion and $2.5 billion to $10 billion. Release.

Amendments to the Stress Testing Rule for National Banks and Federal Savings Associations

 

On October 10, the OCC published a final rule in the Federal Register that will amend the OCC’s stress testing rule at 12 CFR 46. The final rule implements requirements imposed by section 401 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final will raise the minimum asset threshold for national banks and federal savings associations covered by the company-run stress testing requirement from $10 billion to $250 billion in total consolidated assets. Release.

CFPB Issues Final HMDA Rule to Provide Relief to Smaller Institutions

 

On October 10, the Consumer Financial Protection Bureau (CFPB) issued a rule which finalizes certain aspects of its May 2019 Notice of Proposed Rulemaking under the Home Mortgage Disclosure Act (HDMA). It extends for two years the current temporary threshold for collecting and reporting data about open-end lines of credit under the HDMA. The rule also clarifies partial exemptions from certain HMDA requirements which Congress added in the EGRRCPA. Release.

FDIC to Centralize Key Aspects of Its Large, Complex Financial Institution Activities

 

On July 8, the Federal Deposit Insurance Corporation (FDIC) announced its intentions to centralize the supervision and resolution activities for the largest banks and complex financial institutions in a new division to be named the Division of Complex Institution Supervision and Resolution (CISR). The new division will be responsible for the Agency’s supervision and monitoring of banks with assets greater than $100 billion for which the FDIC is not the primary federal regulator. On the resolution side, the new division will be responsible for planning for and executing the FDIC’s resolution mandates for these institutions, as well as for other financial companies if called upon to protect U.S. financial stability. Release.