Thomas Caruso

Associate

New York


Read full biography at www.orrick.com

Thomas Caruso is an associate in the Structured Finance group in the New York office.

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Posts by: Thomas Caruso

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.

Federal Reserve Announces its Paycheck Protection Program Liquidity Facility is Fully Operational and Available to Provide Liquidity to Eligible Financial Institutions

 

On April 16, the Federal Reserve announced that its Paycheck Protection Program Liquidity Facility is fully operational and available to provide liquidity to eligible financial institutions, which will help support small businesses. The Small Business Administration’s Paycheck Protection Program, or PPP, guarantees loans extended by qualified lenders to small businesses so that those businesses can keep workers employed. Release.

FHA Offers Incentives for Property Owners Who Invest in Opportunity Zones

 

On May 9, the Federal Housing Administration (FHA) announced a package of incentives to encourage multifamily property owners to invest in thousands of neighborhoods located in Opportunity Zones across the nation. FHA is introducing reduced application fees paid by property owners applying for certain multifamily mortgage insurance programs for the development or rehabilitation of apartment units located, or proposed to be located, in Opportunity Zones. In addition, FHA is designating teams of senior underwriters to review these applications to ensure the most attentive and timely processing. Press Release. Housing Notice.

Federal Reserve Approves Final Rule to Repeal Regulations that Incorporated the S.A.F.E. Act

 

On May 9, the Federal Reserve Board approved final amendments to its regulations to reflect the transfer of the Board’s rulemaking authority for the Secure and Fair Enforcement for Mortgage Licensing Act (S.A.F.E. Act) to the Consumer Financial Protection Bureau (CFPB). Entities that were subject to the Board’s rules are now subject to the CFPB’s rules. Press Release.

Rating Agency Developments

 

On March 11, Moody’s issued a revised rating methodology for Transactions Backed by Trade Receivable Obligations. Methodology.

On March 8, Fitch issued criteria relating to Counterparty Risk Assessment in Relation to the Assessment of Creditworthiness of Structured Finance and Covered Bond Securities. Criteria.

On March 8, Moody’s issued a revised rating methodology for Collateralized Debt Obligations Backed by Trust Preferred Securities (TruPS CDOs). Methodology.

On March 8, Moody’s issued a revised rating methodology for Collateralized Debt Obligations Backed by Structured Finance Assets (SF CDOs). Methodology.

On March 8, Moody’s issued a revised rating methodology for Corporate Synthetic Collateralized Debt Obligations (CSOs). Methodology.

On March 8, Moody’s issued a revised global approach to rating Collateralized Loan Obligations (CLOs). Global Approach.

On March 7, Moody’s issued a revised rating methodology for Rental Fleet Securitizations. Methodology.

CFTC and MAS Mutually Recognize Certain Derivatives Trading Venues in the U.S. and Singapore

 

On March 13, the Commodity Futures Trading Commission (CFTC) issued an order exempting certain derivatives trading facilities regulated by the Monetary Authority of Singapore (MAS) from the requirement to register with the CFTC as swap execution facilities (SEFs), and MAS announced the issuance of regulations exempting certain derivatives trading venues regulated by the CFTC from the requirement to be a MAS-authorized approved exchange (AE) or recognized market operator (RMO) before establishing or operating an organized market. Press Release. CFTC Order of Exemption. MAS Order of Exemption.

Treasury and USTR Finalize Bilateral Agreement with the UK on Prudential Measures Regarding Insurance and Reinsurance

 

On December 11, the U.S. Department of the Treasury (“Treasury“) and the Office of the U.S. Trade Representative (“USTR“) announced their intent to sign the Bilateral Agreement between the United States of America and the United Kingdom on Prudential Measures Regarding Insurance and Reinsurance (“the U.S.-UK Covered Agreement“). Release.