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Court Dismisses Stockholder Suit Against Meta: Affirms a Firm-Specific Model of Corporate Management

On April 30, 2024, the Delaware Court of Chancery dismissed a stockholder lawsuit against social media giant Meta Platforms, Inc., its board of directors and company founder, Mark Zuckerberg. The decision rejected novel...more

LSTA Issues Guide on Sustainable Loan Principles in Fund Finance

On March 2, 2024, the Loan Syndications and Trading Association (LSTA) announced the publication of the latest addition to its sustainable lending library — the Guide on Sustainability Linked Loan Principles (SLLP) in Fund...more

The 2023 SNC Review Results: Increased Critical Loans Observed

On Feb. 16, 2024, the board of governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and together with the...more

Defaulting Lenders Under Unitranche Facilities

The Loan Syndications and Trading Association (LSTA) defaulting lender provisions were released in 2011 in the aftermath of the 2008 Financial Crisis. Some 12 years later, recent distress in the banking sector has thrust...more

SEC Adopts T+1 Settlement Cycle

On Feb. 15, the Securities and Exchange Commission (SEC) adopted final rule amendments to Exchange Act Rule 15c6-1 to shorten the standard settlement cycle for most securities transactions from two business days after trade...more

Federal Banking Regulators Issue Joint Statement on Crypto-Asset Risks to Banking Organizations

On Jan. 3, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a statement on...more

SEC Staff Provides Relief From Rule 15c2-11 Public Financial Statement Disclosure Through Jan. 5, 2025

On Sept. 16, 2020, the Securities and Exchange Commission (SEC) adopted amended Rule 15c2-11 (the Amended Rule) under the Securities Exchange Act of 1934, as amended (the Exchange Act). The Amended Rule, most of which became...more

Final Treasury Regulations Cushion Potential Tax Ramifications of Vanishing LIBOR

On Jan. 4, 2022, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final regulations (the Final Regulations) offering guidance to taxpayers with respect to the widely reported...more

Federal Bank Regulators Approve New Cybersecurity Incident Notification Rule

On Nov. 18, 2021, federal bank regulatory agencies approved a final rule requiring banking organizations to notify regulators of “any significant computer-security incident” as soon as possible and no later than 36 hours...more

The End of LIBOR

On March 5, 2021, the ICE Benchmark Administration (IBA), UK Financial Conduct Authority (FCA) and International Swaps and Derivatives Association (ISDA) made important announcements regarding the timelines of the cessations...more

SEC Provides Disclosure Guidance on SPAC IPO and Subsequent Business Combination Transactions

On Dec. 22, 2020, the Staff of the Division of Corporation Finance (Staff) issued CF Disclosure Guidance: Topic 11 – Special Purpose Acquisition Companies to provide its views about certain disclosure considerations for...more

How Regulation of Leveraged Lending Will Change Under President Biden

The change in administration that will take place on Jan. 20, 2021, will likely have significant consequences for leveraged lending market participants. The relatively “soft touch” regulatory approach taken by federal...more

GAO Report Finds that Leveraged Lending Has Not Threatened Financial Stability

On Dec. 16, 2020, the U.S. Government Accountability Office (the GAO) issued a report to the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Department of the Treasury, the...more

SEC Adopts Amendments to MD&A and Financial Disclosures

On Nov. 19, 2020, the U.S. Securities and Exchange Commission (SEC) adopted amendments to the disclosure rules affecting Management’s Discussion and Analysis (MD&A) and related financial disclosures. ...more

LIBOR Benchmark Administrator to Cease Publication of One-Week and Two-Month U.S. Dollar LIBOR on Dec. 31, 2021, and the Remaining...

On Nov. 30, 2020, Intercontinental Exchange, Inc. announced that ICE Benchmark Administration Limited (IBA) is proposing the cessation of the publication of  the one-week and two-month U.S. dollar LIBOR on Dec. 31, 2021, and...more

Trump Administration Proposes Rule to Thwart Resurrection of Leveraged Lending Guidance

On Nov. 5, the federal banking regulatory agencies (the Agencies) gave notice of a proposed rule (the Proposed Rule) that would elevate to the status of a formal rule and enhance the Agencies’ current policy of not issuing...more

New CDI Clarifies the Form S-3 Eligibility of Companies That Go Public via Merger into a SPAC

On Sept. 21, 2020, SEC’s Division of Corporation Finance (Corp Fin) posted a Compliance and Disclosure Interpretation (CDI) regarding restrictions on Form S-3 eligibility for private companies that go public via merger into a...more

FSB and BCBS Report on Supervisory Issues Associated With Benchmark Transition

On July 9, the Financial Stability Board (FSB) and the Basel Committee on Banking Supervision (BCBS) published a report on the findings of surveys on supervisory issues related to LIBOR transition undertaken by the FSB, the...more

OCIE’s Risk Alert on LIBOR Transition Preparedness

In January 2020, the Office of Compliance Inspections and Examinations (OCIE) included London Interbank Offered Rate (LIBOR) preparedness as an examination program priority in its 2020 Examination Priorities (2020...more

Kirschner v. JPMorgan Chase Holds that Syndicated Bank Loans Are Not Securities

On May 22, Judge Gardephe granted a motion to dismiss in Kirschner v. JPMorgan Chase Bank, N.A., a case that, among other things, considered whether the origination and distribution of a syndicated bank loan is subject to...more

How the SEC’s Amendments to Financial Disclosures for Acquisitions Affect High-Yield Bond Offerings

On May 21, the Securities and Exchange Commission (SEC) adopted amendments to its rules governing financial disclosures relating to acquisitions and dispositions of businesses. ...more

COVID-19 Update: Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working With Customers...

On March 22, 2020, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (the NCUA), the Office of the Comptroller of the...more

Gov. Cuomo Issues Executive Order Deeming it an ‘Unsafe and Unsound Business Practice’ for New York Banks to Not Grant 90-Day...

On March 21, 2020, New York Gov. Andrew Cuomo issued Executive Order No. 202.9, pursuant to his broad emergency powers to temporarily suspend or modify statutes, local laws, ordinances, rules and regulations during periods of...more

Sen. Elizabeth Warren Demands Leveraged Loan Data From FSOC Amid Pandemic

On March 20, Sen. Elizabeth Warren, D-Mass., disclosed to certain news outlets that she had sent a letter, dated March 19, to Steven T. Mnuchin, secretary of the treasury, in his capacity as chair of the Financial Stability...more

Statement from the Loan Syndications and Trading Association Regarding Business Continuity in the Corporate Loan Market

On March 9, the Loan Syndications and Trading Association (“LSTA”), the association for the syndicated loan market in the United States, announced that it members are taking multiple steps to ensure business continuity and a...more

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