Our Finance Group summarizes the Securities and Exchange Commission’s finalized Rule 192 that prohibits conflicts of interest among participants in asset-backed securitizations. - The Dodd–Frank Act prohibits conflicts...more
On January 25, 2023, the Securities and Exchange Commission (“SEC” or “Commission”) issued a release (the “Re-Proposal”) proposing Rule 192 under the Securities Act of 1933, as amended (the “Securities Act”), a rule that is...more
Executive Summary - The Securities and Exchange Commission (the “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...more
On January 25, 2023, the SEC reproposed its 2011 proposed rule to prohibit certain securitization participants from engaging in transactions that present conflicts of interest vis-à-vis ABS investors. This note answers a...more
The challenges of complying with both the US rules and the EU rules. Both United States and European Union laws now require 5 percent credit risk retention for securitization transactions. While the jurisdictional scope...more