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
Structured Finance
SEC Adopts Final Rules Removing Credit Ratings References from Regulation M
On June 7, 2023, the US Securities and Exchange Commission (the “SEC”) unanimously adopted final rules amending Regulation M (the “Final Rules”) to remove its references to credit ratings, replace them with alternative measures of creditworthiness and impose related record-keeping obligations on broker-dealers. The SEC had previously proposed amendments to Regulation M (the “Proposed Rules”)…
SEC Re-Proposes Conflict of Interest Rule for Asset Backed Securities
The Securities and Exchange Commission (“SEC”) has issued proposed Rule 192 pursuant to Section 27B of the Securities Act of 1933. Section 27B requires the SEC to issue rules for the purpose of implementing that section’s prohibition against a securitization participant’s entering into a transaction that would involve or result in a material conflict of…
Commercial Paper Legal and Regulatory Developments
January 24, 2023 Webinar
1:00 pm – 2:00 pm ET
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During the session hosted by the Practising Law Institute, Mayer Brown Partner, Jerry Marlatt, and Robert Crowe, Head of Money Markets Origination at Citigroup Global Markets, will discuss the various trends contributing to increased interest in commercial paper financing, as well as…
Understanding Structured Debt and Private Convertibles
January 20, 2023 Webinar
12:00 pm – 1:00 pm ET
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2022 was a year marked by the market’s increasing preference for structured financing alternatives. During this session, panelists Syed Raj Imteaz and Anna Shearer of ICR Capital joined by Mayer Brown’s Anna Pinedo will discuss market trends within the structured debt and…
SEC Staff Grants Temporary Relief from Compliance with Rule 15c2-11 for Rule 144A Fixed Income Securities
With the January 3, 2023, deadline fast approaching for compliance with Exchange Act Rule 15c2-11, as amended and reinterpreted by the staff of the US Securities and Exchange Commission (“SEC”) to apply to fixed income securities (the “Rule”), the SEC staff granted some temporary relief in a new no-action letter on November 30. Participants in…
Everything Old is New Again: Commercial Paper Market and Regulatory Developments
December 7, 2022 Webinar
1:00 pm – 2:00 pm EST
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Over the years, there have been significant fluctuations in the asset-backed commercial paper market, however, the market has also demonstrated its resiliency and adaptability. Collateralized commercial paper and commercial paper conduit programs have recently become increasingly significant. Asset-backed commercial paper levels for…
SEC Proposes to Remove Credit Ratings References from Regulation M
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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Legal Update: Proposed Revisions to Volcker Rule Covered Funds Provisions
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…
Beyond Auto Leasing: The Use of Titling Trusts in Structured Finance Transactions
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…