Posts by: Thomas Caruso

Rating Agency Developments


On April 3, DBRS updated its North American CMBS Multi-borrower Rating Methodology. Release.

On April 3, Fitch issued rating criteria for RMBS Lenders’ Mortgage Insurance. Release.

On April 3, Moody’s updated its rating methodology for the Mining Industry. Release.

On April 3, Moody’s updated its rating methodology for the Passenger Airline Industry. Release.

On March 28, 2018, Moody’s issued a statement that its US retail REITs generally will not be affected by Toys R Us’ plans to liquidate all its US Stores. Release.

Federal Banking Agencies Issue Final Rule to Exempt Commercial Real Estate Transactions of $500,000 or Less from Appraisal Requirements:


On April 2, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule that increases the threshold for commercial real estate transactions requiring an appraisal from $250,000 to $500,000. Press Release. Rule.

SEC Adopts Statement and Interpretive Guidance on Public Company Cybersecurity Disclosures


On February 20, the SEC approved a statement and interpretive guidance to assist public companies in preparing disclosure about cybersecurity risks and incidents. The guidance provides the SEC’s views about public companies’ disclosure obligations under existing law with respect to matters involving cybersecurity risk and incidents. Press release. Guidance.

Agencies Seek Comment on Proposed Amendments to Swap Margin Rule


On February 5, five federal agencies (the Farm Credit Administration, FDIC, Federal Housing Finance Agency, Federal Reserve and Office of the Comptroller of the Currency) proposed to amend swap margin requirements to conform with recent rule changes that impose new restrictions on certain qualified financial contracts of systemically important banking organizations. Under the proposed amendments, legacy swaps entered into before the applicable compliance date would not become subject to the margin requirements if they are amended solely to comply with the requirements of the qualified financial contract rules. Press Release. Proposed Rule.