A broker-dealer failed to reasonably supervise its registered representatives when making recommendations of certain variable rate structured products (“VRSPs”), including fixed to floating rate steepeners and other variable...more
With some of the nation’s largest real estate owners defaulting on, and looking to restructure, loans backed by commercial office buildings, what may have seemed like an impossibility a few short years ago, is now very much a...more
According to the Consumer Price Index (CPI), the United States is facing the highest inflation numbers in over 40 years. On April 12, 2022, it was announced that the CPI has increased 8.5% over the last 12 months, based on...more
Financial institutions should work with outside counsel to ensure that their internal policies and external actions minimize conduct that may violate state and Federal laws and regulations, and incentivize employees to reward...more
In late September, the Pension Benefit Guaranty Corporation (the “PBGC”) published Press Release 20-04 and issued Technical Update 20-2 providing flexibility in the calculation of variable-rate premiums for plan sponsors who...more
Borrowers under variable rate commercial loans commonly enter into interest rate hedge agreements to eliminate or reduce their exposure to the interest rate risk of their variable debt service obligations. ...more
Many clients have been asking questions relating to the current market challenges with VRDOs and CP (high interest rates and lack of demand). The discussion below was drafted to provide some basic information and analysis...more
On November 20, Republican Senators Charles Grassley and Lamar Alexander – chairmen of the committees with jurisdiction over pensions – jointly released the Multiemployer Pension Recapitalization and Reformation Plan (the...more
Many conduit tax exempt revenue bonds bear interest at a floating rate, most typically a percent of USD 1-month LIBOR (here, LIBOR). Many of these transactions have been synthetically “fixed” by the conduit borrower entering...more
On October 9, 2019, the U.S. Department of the Treasury and the Internal Revenue Service proposed regulations (“Proposed Regulations”) addressing the transition from London interbank offered rate (“LIBOR”) to the use of...more