On March 23, 2022, the US Securities and Exchange Commission (the “SEC”) proposed amendments to remove references to credit ratings from Regulation M, replace them with alternative measures of creditworthiness and impose related recordkeeping obligations on broker-dealers (the “Proposal”). Our Legal Update discusses key elements of the SEC’s Proposal.

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On January 30, 2020, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the Commodity Futures Trading Commission proposed revisions to the covered funds provisions of the Volcker Rule. The proposal is intended to address the

A primary feature of most structured finance transactions is the initial transfer of the assets being financed. The time, effort, and expenses of an asset transfer may be an impediment to the execution of a successful transaction. For decades, auto lease transactions have mitigated this impediment through the use of titling trusts, which allow for