On September 26, 2025, the Securities and Exchange Commission published a concept release requesting comments on whether to amend the asset-level disclosure requirements for residential mortgage-backed securities (RMBS) in Item 1125 of Regulation AB. The release solicits comments on whether to revise the definition of “asset-backed security” and/or other definitions in Item 1101 of Regulation AB.
US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform
Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”). This proposal is intended to reduce the likelihood of the eSLR requirement being the binding capital constraint for US GSIBs and, thereby, enhance the ability of US GSIBs
Sustainable Commercial Paper: Short-Term Paper, Long-Term Impact
Over the past few years, we have seen growing interest in Commercial Paper (CP) programmes with a sustainable focus.
Traditionally used by corporations, financial institutions, sovereigns, and other issuers for short-term liquidity needs, CP is now being adapted to align with environmental, social, and governance (ESG) objectives.
The International Capital Market Association (ICMA) has recognised
FSB Raises Concerns With CP and CD Markets
The Financial Stability Board (FSB) recently issued a report on vulnerabilities in the markets for commercial paper (CP) and negotiable certificates of deposit (CDs). The report analyzes the structure of the markets, identifies vulnerabilities, and suggests reforms that policy makers might consider. It acknowledges that limitations exist, and, therefore, the adoption of the reforms will
At A Glance: Covered Bonds in 2023
Following the financial sector disruptions in 2023, financial institutions turned first to covered bonds for funding and the covered bond market demonstrated its resilience. Just as the covered bond market remained available through the financial crisis in 2008 through 2010, it remained a safe harbor in recent times. Now, four continents (in addition to Europe)
SEC Adopts Climate Change Disclosure Rules Applicable to Public Companies and Offerings
The Securities and Exchange Commission (the “SEC”) has adopted new rules that require public companies to disclose substantial information about the material impacts of climate-related risks on their business, financial condition, and governance (the “Final Rules”). The SEC says that “climate-related risks, their impacts, and a public company’s response to those risks can significantly affect
White Paper: The Final Stretch: Securitization in the US Under the Proposed Basel III Endgame Rules
On July 27, 2023, the US banking regulators issued a proposal to significantly revise the risk-based capital requirements applicable to large banks and to banks with significant trading activity. The proposal, which is colloquially referred to as “Basel III Endgame” or “Basel IV,” includes important changes to the calculation of credit risk weights for securitization
Long-Term Debt Requirements Proposed for US Regional Banks
On August 29, 2023, US federal banking regulators issued a proposal for long-term debt (“LTD”) requirements on certain midsize and larger US banking organizations (the “LTD Proposal”). The LTD Proposal is important because it would require many regional and larger banking organizations to issue significant amounts of LTD. In this Legal Update, we provide background
A Road Not Taken: Where the US Capital Proposal Differs From Basel
On July 27, 2023, US federal banking regulators issued proposals to significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and change the method for calculating the capital surcharge for global systemically important banking organizations (“G-SIBs”). These proposals are of critical importance because the amount of
Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and (ii) change the method for calculating the capital surcharge for globally systemically important banking organizations (“G-SIBs”) (the “G-SIB Surcharge Proposal”). These proposals are of