Robert Moyle

Partner

New York

rmoyle@orrick.com

Read full biography at www.orrick.com

Robert Moyle is a partner in Orrick’s New York office. Rob’s practice focuses on securitization, public offerings and private placements, as well as other types of asset financings and sales.

Rob has experience with a wide variety of asset classes, including credit and charge card receivables, auto loans and leases, dealer floorplan receivables, consumer and small business loans, student loans, tender option bonds and residential mortgages. He represents a variety of market participants, including issuers, sponsors, underwriters, placement and remarketing agents, lenders, borrowers and liquidity providers. Rob also advises clients on the application of securities laws and other financial industry regulations, including Regulation AB II and the rules and regulations promulgated under the Dodd-Frank Act.

Rob joined Orrick in 2005. He serves as Hiring Partner in the New York Office and is a member of the firm’s Professional Development Committee.

Posts by: Robert B. Moyle

Treasury Request for Public Input on Expanding Access to Credit through Online Marketplace Lending

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“Online marketplace lending refers to the segment of the financial services industry that uses investment capital and data-driven online platforms to lend to small businesses and consumers.”[1]

On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including –

  • the business models and products offered to small businesses and consumers
  • the potential to expand access to credit to underserved market segments
  • how the financial regulatory framework should evolve to support the growth of the industry
  • Treasury asks for comment on 14 categories of questions, some of which include multiple specific questions, which we summarize and, with respect to some, offer initial thoughts on below.

To view the full article, please click here.

[1] 80 Fed. Reg. 42866 (July 20, 2015)

FDIC, Federal Reserve and Office of Comptroller of the Currency Reiterate Annual Public Disclosure Requirements for Medium-Sized Financial Companies Under Dodd-Frank Company-Run Stress Tests

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On June 2, the Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve System and Office of the Comptroller of the Currency reiterated the disclosure requirements for annual stress tests conducted by financial institutions with total consolidated assets between $10 billion and $50 billion pursuant to the Dodd-Frank Act. The medium-sized firms are required to disclose certain information, including: a description of the types of risks included in the stress test; a summary description of the methodologies used in the stress test; estimates of losses, revenue, and net income; post-stress capital ratios; and an explanation of the most significant causes for the changes in regulatory capital ratios.  Joint Release.

SEC Provides Additional Analysis Related to Proposed Pay Ratio Disclosure Rules

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On June 4, the Securities and Exchange Commission provided additional analysis related to its proposed rules for pay ratio disclosure.  The staff believes that the analysis will be informative for evaluating the potential effects on the accuracy of the pay ratio calculation of excluding different percentages of certain categories of employees, such as employees in foreign countries, part-time, seasonal, or temporary employees as suggested by commenters.  The staff is making the analysis available for public comment – comments may be submitted by July 6.  Release.  Analysis.

Rating Agency Developments

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On June 1, DBRS released its RMBS Insight 1.2:  U.S. Residential Mortgage-Backed Securities Model and Rating Methodology.  Report.

On June 1, Fitch released its U.S. RMBS Surveillance and Re-REMIC Criteria.  Report.

On June 1, Moody’s issued RMBS Rating Methodology Supplement – Israel.  Report.

On June 1, S&P issued Revised Assumptions For Rating U.S. RMBS Prime, Alternative-A, And Subprime Loans Incorporated Into LEVELS Version 7.4.3, effective immediately.  Report.

On June 1, S&P issued Revised U.S. Residential Mortgage Input File Format, Glossary, And Appendices To The Glossary For LEVELS Version 7.4.3, effective immediately.  Report.

On June 2, Fitch released its State Housing Finance Agencies:  MBS Pass-Through Bond Rating Criteria.  Report.

On June 3, Fitch released its Criteria for Rating U.S. Timeshare Loan ABS.  Report.

On June 5, Fitch released its U.S. Nonprofit Institutions Rating Criteria.  Report.

On June 5, S&P released its Global Container Lease-Backed ABS Methodology And Assumptions.  Report.

Rating Agency Developments

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On May 29, DBRS released its updated methodology for rating U.S. asset-backed commercial paper.  Report.

On May 29, Fitch republished its criteria for rating supranationals.  Report.

On May 28, Fitch released its updated criteria for rating new-issue U.S. and Canadian multiborrower CMBS.  Report.

On May 28, Fitch released its updated criteria for rating solar power projects.  Report.

On May 27, DBRS released its updated methodology for operational risk assessment of U.S. ABS servicers.  Report.

On May 27, Moody’s released its global methodology for rating reverse mortgage securitizations.  Report.

On May 26, KBRA released its methodology for rating full-recourse secured aircraft-debt instruments issued by airlines and aircraft lessors.  Report.

 

Federal Reserve Proposes Adding Additional Asset Types to Meet LCR Requirements

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On May 21, the Federal Reserve Board proposed adding certain general obligation state and municipal bonds to the range of assets a banking organization may use to satisfy the Liquidity Coverage Ratio (LCR) requirements designed to ensure that large banking organizations have the capacity to meet their liquidity needs during a period of financial stress.  Subject to specified limits, the proposed rule would allow investment grade, general obligation U.S. state and municipal bonds to be counted as high-quality liquid assets (HQLA) up to certain levels if they meet the same liquidity criteria that currently apply to corporate debt securities.  Release.  Proposal.

Fannie Mae and Freddie Mac to Issue New Seller/Servicer Eligibility Requirements

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On May 20, the FHFA announced that Fannie Mae and Freddie Mac are issuing new finalized operational and financial eligibility requirements for mortgage seller/servicers.  The updated requirements will be communicated through guides, bulletins and announcements and through best practices documents provided by Fannie and Freddie.  The operational requirements become effective no later than September 1, 2015 and the financial requirements become effective December 31, 2015.  Release.  Fannie Mae and Freddie Mac FAQs.

FHFA Releases Update on the Single Security Project

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On May 15, the FHFA released an update on the structure of the Single Security, a project involving the development of a single mortgage-backed security that would be issued by Fannie Mae or Freddie Mac.  The update contains FHFA’s decisions made in response to input previously provided by industry stakeholders.  Release.  Update.

Rating Agency Developments

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On May 22, DBRS released its methodology for rating entities in the real estate industry.  Report.

On May 21, DBRS released its methodology for reviewing ratings of Canadian structured finance and covered bond transactions.  Report.

On May 20, Moody’s released its methodology for rating trade receivables-backed transactions.  Report.

On May 20, Moody’s released its methodology for rating “credit tenant lease” (CTL) obligations.  Report.

On May 20, Moody’s released its methodology for rating corporate synthetic collateralized debt obligations (CSOs).  Report.

On May 19, Moody’s released its methodology for rating commercial mortgage backed securities (CMBS) in Europe, Middle East and Africa (EMEA).  Report.

On May 19, Fitch released its updated criteria for rating global aircraft operating lease ABS.  Report.

On May 18, Fitch updated its International Local and Regional Government Ratings Criteria.  Report.

On May 18, Fitch updated its U.S. Public Power Rating Criteria.  Report.

CFTC Issues Guidance for Swap Execution Facilities on the Calculation of Projected Operating Costs

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On April 23, the CFTC issued guidance regarding the calculation of projected operating costs or expenses for the purpose of meeting the financial resource requirements under SEF Core Principle 13 in Section 5h(13) of the Commodity Exchange Act and Commission Regulation 37.1303.  Release.  CFTC Letter.