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Posts by: William Cavanagh

Rating Agency Developments

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On October 16, DBRS published an update to its ratings methodology for: Rating U.S. Rental Car Securitizations. Release.

On October 16, DBRS published an update to its ratings methodology for: Rating U.S. Property Assessed Clean Energy (“PACE”) Securitizations. Release.

On October 16, Fitch published an update to its rating criteria for: Trade Receivables Securitization Rating Criteria. Release.

On October 15, Fitch published an update to its rating criteria for: U.S. CREL CDO Surveillance Criteria. Release.

On October 12, DBRS published an updated report entitled: Rating Canadian Auto Retail Loan and Lease Securitizations. Release.

On October 12, DBRS published an updated report entitled: Rating Canadian Auto Fleet Lease Transactions. Release.

On October 12, DBRS published an updated report entitled: Rating Canadian Rental Car Fleet Securitizations. Release.

On October 12, DBRS published an updated report entitled: Rating Canadian Equipment Finance Securitization Transactions. Release.

On October 12, DBRS published an updated report entitled: Rating Canadian Wholesale Securitizations. Release.

SEC Adopts Amendments to Simplify and Update Disclosure Requirements

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On August 17, 2018, the Securities and Exchange Commission announced it voted to adopt amendments to certain disclosure requirements that it found have become duplicative, overlapping or outdated in light of other Commission disclosure requirements, U.S. Generally Accepted Accounting Principles (“GAAP“) or changes in the information environment. The Commission also announced it is referring certain disclosure requirements that overlap with, but require information incremental to, GAAP to the Financial Accounting Standards Board for consideration for potential incorporation into GAAP. Press Release. Final Rule.

SEC Adopts Rule Amendments to Improve Municipal Securities Disclosure

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On August 20, 2018, the Securities and Exchange Commission adopted amendments to Rule 15c2-12 of the Securities Exchange Act in order to enhance transparency in the municipal securities market. The adopted changes focus on material financial obligations that could impact an issuer’s liquidity, overall creditworthiness or an existing security holder’s rights. The amendments add two new events to Rule 15c2-12 of the Securities Exchange Act, which requires brokers, dealers and municipal securities dealers that are acting as underwriters in primary offerings of municipal securities to reasonably determine that the issuer or obligated person has agreed to provide to the Municipal Securities Rulemaking Board timely notice of certain events. Press Release. Final Rule.

CFTC Adopts Rule Amendments Simplifying CCO Duties and Annual Report Rules

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On August 21, 2018, the Commodity Futures Trading Commission (“CFTC“) unanimously approved final amendments clarifying and simplifying its regulations governing chief compliance officer (“CCO“) duties and annual compliance reporting requirements for futures commission merchants (“FCM“), swap dealers and major swap participants. The amendments aim to clarify a CCO’s duties by providing reasonable standards and guidance on effective compliance. The amendments also modify the CCO annual report content and submission requirements to reduce report preparation burdens while also making the reports more effective. Press Release. Final Rule.

CFTC Staff Issues Interpretive Guidance Regarding Exemption from Aggregation

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On May 2, 2018, the Commodity Futures Trading Commission’s (“CFTC“) Division of Market Oversight issued a CFTC staff letter with interpretive guidance regarding CFTC Regulation 150.4(b)(1), an exemption from position aggregation requirements for certain commodity pool investors. According to the staff letter, an institutional investor is not required to look through its investment in a fund to aggregate commodity investment positions of an underlying portfolio company in which such investor may hold a 10% or greater indirect interest when such investor qualifies for the Regulation 150.4(b)(1) exemption from position aggregation. Press Release. Staff Letter.

Rating Agency Developments

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On May 2, 2018, Fitch published a report entitled: Germany Residential Mortgage Rating Criteria Addendum. Release.

On May 2, 2018, Fitch published a report entitled: Switzerland Residential Mortgage Rating Criteria Addendum. Release.

On May 2, 2018, DBRS published a report entitled: Rating Credit Funds. Release.

On May 1, 2018, Fitch published a report entitled: EMEA RMBS Rating Criteria. Release.

On April 26, 2018, Moody’s published its methodology for rating Banks. Release.

Rating Agency Developments

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On November 27, 2017, Fitch issued a report entitled: Exposure Draft: Government-Related Entities Rating Criteria. Release.

On November 27, 2017, Fitch issued a report entitled: Emerging Market Countries’ Local and Regional Governments’ Specific Securities Rating Criteria. Release.

On November 27, 2017, Fitch issued a report entitled: Airports Rating Criteria. Release.

On November 27, 2017, DBRS issued a report entitled: Rating Sovereign Governments. Release.

On November 27, 2017, DBRS issued a report entitled: Global Methodology for Rating Life and P&C Insurance Companies and Insurance Organizations – Request for Comments. Release.

On November 27, 2017, DBRS issued a report entitled: Rating Structured Finance CDO Restructurings – Request for Comments. Release.

On November 28, 2017, Moody’s published an update to its ratings methodology for: US Public Power Electric Utilities With Generation Ownership Exposure. Release.

On November 28, 2017, KBRA issued a report entitled: Global Credit Card ABS Rating Methodology. Release.

On November 28, 2017, KBRA issued a report entitled: Global Container Leasing ABS Rating Methodology. Release.

On November 28, 2017, KBRA issued a report entitled: Global Auto Loan ABS Rating Methodology. Release.

On November 28, 2017, KBRA issued a report entitled: Global Consumer Loan ABS Rating Methodology. Release.

On November 28, 2017, KBRA issued a report entitled: Global Aviation ABS Rating Methodology. Release.

On November 28, 2017, KBRA issued a report entitled: Global General Rating Methodology for Asset-Backed Securities. Release.

On November 28, 2017, KBRA issued a report entitled: Global Equipment Lease & Loan ABS Rating. Release.

FHFA Announces Maximum Conforming Loan Limits for 2018

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On November 28, 2017, the Federal Housing Finance Agency (“FHFA“) announced the maximum conforming loan limits for mortgages to be acquired by Fannie Mae and Freddie Mac in 2018. In most of the U.S., the 2018 maximum conforming loan limit for one-unit properties will be increased to $453,100, from $424,100 in 2017.  In addition, for areas in which 115% of the local median home value exceeds the baseline conforming loan limit, the maximum loan limit will be higher than the baseline loan limit. The new ceiling loan limit for one-unit properties in most high-cost areas will be $679,650, or 150% of $453,100. Release.

Rating Agency Developments

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On November 1, 2017, DBRS issued a report entitled: Rating Canadian Trade Receivables Securitization Transactions. Report

On November 1, 2017, DBRS issued a report entitled: Rating Canadian Credit Card and Personal Line of Credit Securitizations. Report

On November 1, 2017, Moody’s published an update to its ratings methodology for: Not-For-Profit Healthcare. Report

On October 31, 2017, Fitch issued a report entitled: EMEA Equity Release Mortgage Bespoke Rating Criteria. Report

On October 30, 2017, DBRS issued a report entitled: Global Methodology for Rating Secured Obligations of Finance Companies. Report

On October 30, 2017, Moody’s published an update to its ratings methodology for: Public Port Revenue Bonds. Research

On October 30, 2017, Moody’s published an update to its ratings methodology for: Privately Managed Toll Roads. Research

On October 27, 2017, Fitch issued a report entitled: European RMBS Rating Criteria. Report

On October 27, 2017, Fitch issued a report entitled: EMEA RMBS Rating Criteria. Report

On October 26, 2017, Moody’s published an update to its ratings methodology for: Notching Corporate Instrument Ratings Based on Differences in Security and Priority of Claim. Research