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

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.

Rating Agency Developments

 

On November 20, DBRS issued a report outlining its methodology for rating European Structured Finance Transactions. Release

On November 19, Fitch issued rating criteria for Dealer Floorplan ABS. Release

On November 19, Moody’s issued a revised methodology for rating UK Income-Contingent-Repayment Student Loan-Backed ABS. Release

On November 19, Moody’s issued a global approach for rating ABS Backed by Production-Dependent Solar Contracts. Release

On November 15, DBRS issued a report outlining its methodology for rating Canadian Trade Receivables Securitization Transactions. Release

On November 15, Moody’s issued a revised methodology for rating Covered Bonds. Release

On November 15, Moody’s issued a revised methodology for monitoring Scheduled Amortization UK Student Loan-Backed Securities. Release

On November 15, Moody’s issued a revised methodology for rating Insurance Premium Finance-Backed Securities. Release READ MORE

CFTC Approves a Final Rule to Amend Uncleared Swap Margin Requirements

 

On November 19, the Commodity Futures Trading Commission (“CFTC”) announced that it approved a final rule to amend its uncleared swap margin requirements to better align with certain rules adopted by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency that impose restrictions on certain qualified financial contracts. Press release. Rule.