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US Banking Regulators Finalize Nonbank Lending Reporting Requirements

On May 22, 2024, the US federal banking regulators finalized a new set of reporting requirements for bank loans and commitments to fund finance facilities, private credit lenders, and other nonbank financial entities.This...more

Private Credit Reporting Requirements Proposed by US Banking Regulators

On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more

The Private Fund Adviser Rule and the Kirschner Decision: An August Doubleheader

The regulatory and judicial developments of the last few days relating to the loan markets and to loan funds have been significant. On Tuesday, lenders and borrowers were concerned about a world in which syndicated and...more

Structured Finance Bulletin - Winter 2020

The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more

Volcker Rule Revision Complete: Easing the Compliance Burden for Banks

On June 25, 2020, five federal financial regulatory agencies published the long awaited Final Revisions to the Volcker Rule (the “Final Revisions”) which revise certain aspects of the Volcker Rule (Section 13 of the Bank...more

TALF 2020 and CLOs: Progress in the Right Direction, but Has Enough Changed?

On May 12, 2020, the Federal Reserve Bank of New York (the “New York Fed”) announced the issuance of updated Terms and Conditions1 and a Frequently Asked Questions document (the “FAQs”)2 regarding the 2020 Term Asset-Backed...more

U.S. Federal Reserve Expands and Provides Additional Details on Main Street Lending Program for Small and Mid-Sized Businesses

On April 30, 2020, the Federal Reserve Board announced expanded loan offerings and terms for the forthcoming Main Street Lending Program. Among other changes, Main Street is now open to larger businesses with up to 15,000...more

TALF 2020 and CLOs

On April 9, 2020, the U.S. Federal Reserve announced revised preliminary terms for the Term Asset-Backed Securities Loan Facility ("TALF 2020"). Certain CLO securities that are rated AAA by at least two rating agencies and...more

The CARES Act and CLOs

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act, was signed into law.  Among other things, Section 4003 of the CARES Act authorizes $500 billion of liquidity to support businesses,...more

Legal Update on Section 4003 of the CARES Act – Liquidity for Eligible Businesses, States, and Municipalities

The Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act, was signed into law by President Trump on March 27, 2020. A central element of the new law is the authorization of the Secretary of the Treasury, under...more

Fed support for at least short term ABCP markets looks quite promising

The disruptions in economic conditions caused by the coronavirus disease 2019 (COVID-19) are reaching the commercial paper and longer term debt capital  markets.  The Board of Governors of the Federal Reserve System (Federal...more

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