Weekly Brief: DOJ Memo Details Justification For Killing US Citizens
Will The Debt Ceiling Standoff End Up In Court?
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. In fact, some of those flaws are so bad that they left the Trump Administration with only 2 choices,...more
Securitisation of subscription finance facilities is en vogue in fund finance. We have written previously on this topic, offering a primer on capital call securitisations and a Q&A regarding a first publicly rated cash...more
“Illinois doubled private investments in the state, as well as investments in clean energy, and quadrupled the number of retained jobs in 2024, the Illinois Department of Commerce and Economic Opportunity said this week....more
The European Securities and Markets Authority has published technical advice on revisions to Delegated Regulation (EU) 447/2012 and Annex I of the CRA Regulation...more
The National Association of Insurance Commissioners (NAIC) held its Summer National Meeting, at which it adopted new guidelines allowing state regulators or NAIC staff to override formerly automatic ratings on investments....more
On August 7, the CFPB issued a report and a consumer advisory highlighting predatory practices in solar lending. On the same day, the FTC released a blog post emphasizing similar concerns....more
Connecticut Governor Ned Lamont recently signed a new bill into law that prohibits healthcare providers from reporting patients’ medical debt to credit rating agencies. The law goes into effect on July 1, 2024. In addition,...more
One of the best things about fund finance is that there is always something new and exciting happening in our space. New players come online, and new products and solutions solve issues that pave the way for fund borrowers to...more
New and additional bonding requirements for certain companies operating on the Outer Continental Shelf (“OCS”) will take effect in June as a result of a recent rulemaking. These new requirements will be phased in over a...more
For a decade, the U.S. Department of the Interior has wrestled with financial assurance (or bonding) requirements for offshore oil and gas companies. Over the last 10 years, the Interior Department has released – and later...more
In this week’s edition, we discuss the EU’s continued push to develop its ESG regulatory framework by proposing changes to the regulation of credit ratings agencies to accommodate ESG factors. Regulating ESG ratings providers...more
On 14 March 2024, China’s National Development and Reform and Commission (NDRC) issued a consultation paper soliciting public comments on its proposed rules providing support for the incurrence of the medium- and long-term...more
The Cozen Lens- •As bipartisanship wanes, forced compromise remains an essential component of governance in Washington, DC. - •Dealmaking activity is up, but antitrust enforcement is also expected to increase as growing...more
The FCA found that wholesale data markets can be improved, but has ruled out a significant intervention. The FCA has published the findings of its wholesale data market study (MS23/1.5), which examined competition in the...more
The U.S. Supreme Court has ruled that federal government agencies can be held liable under the Fair Credit Reporting Act when they fail to investigate or correct inaccurate information furnished to credit reporting agencies. ...more
Colorado is in the headlines again. On January 29, a bill was introduced in the Colorado legislature to include certain additional charges in the total amount of finance charges subject to rate limits under the Colorado...more
Interest rates and inflation have been the big drivers of the US economy as of late, but lenders are increasingly optimistic for 2024, despite some challenges. Lenders foresee interest rate declines beginning in 2024 – with...more
On November 6, the Fed released its quarterly survey of Senior Loan Officer Opinion Survey (SLOOS) on bank lending practices. The report is administered to mostly domestic banks but includes some international banks....more
Today, maximizing the use of your limited capital is especially important because: margins continue to be squeezed, access to capital has become more difficult, the cost of capital continues to rise, the cost of...more
In recent years, U.S. banks have been tightening lending conditions. This trend is expected to continue for commercial loans because of various factors, including the ongoing effects of the COVID-19 pandemic, changes in...more
Earlier this week, Moody’s Investor Services downgraded the credit ratings of 10 regional banks and put 17 other banks under review or gave their rating a negative outlook. Notwithstanding the downgrades, most of the...more
The Biden administration has proposed changes regarding when oil, gas, and sulfur lessees and certain other parties operating in the offshore Outer Continental Shelf must post additional bonds or other “supplemental financial...more
On June 29, 2023, the Department of Interior’s Bureau of Ocean Energy Management (BOEM) published a proposed rule that, if adopted, would substantially revise the financial assurance requirements applicable to offshore oil...more
The EU published a new Sustainable finance package 2023 on June 13, 2023. The package includes - - A Proposed Regulation on the transparency and integrity of ESG rating activities, which aims to enhance the quality of ESG...more
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...more