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Articles by Ryan Suda
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.1 This change reflects not only the rapid growth in this sector, but also the regulators' desire to better understand and supervise concentrations of credit and risk in the US banking system.
Volcker Rule Revision Complete: Easing the Compliance Burden for Banks | Lexology
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 Holding Company Act) with respect to the identification and treatment of covered funds.
Volcker Rule Revision Complete—Easing The Compliance Burden For Banks - Finance and Banking - United States
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TALF 2020 And CLOs: Progress In The Right Direction, But Has Enough Changed?
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
TALF 2020 Update: MLSA, Revised FAQs and Related Program Materials
On May 20, 2020, the Federal Reserve Bank of New York (“FRBNY” or the “Fed”) announced the first subscription date, June 17, 2020, in connection with the Term Asset-Backed Securities Loan Facility (“TALF 2020”). The Fed also issued revised Frequently Asked Questions (“FAQs”) and the new Master Loan and Security Agreement (“MLSA”) for the program, along with other updated forms and documents.
TALF 2020 and CLOs: Progress in the Right Direction, but Has Enough Changed?
On May 12, 2020, the Federal Reserve Bank of New York announced the issuance of updated Terms and Conditions and a Frequently Asked Questions document (the “FAQs”) regarding the 2020 Term Asset-Backed Securities Loan Facility (“TALF 2020”). In this Legal Update, we discuss several aspects of the updated TALF 2020 documents with particular relevance to CLOs, including several welcome improvements and a few drawbacks.
TALF 2020 Update: Federal Reserve Bank of New York Releases FAQs and Revised Term Sheet
On May 12, 2020, the Federal Reserve Bank of New York (the “Fed”) issued new Frequently Asked Questions and a revised term sheet in connection with the Term Asset-Backed Securities Loan Facility (“TALF 2020”). This Legal Update summarizes the FAQs and the revised term sheet, highlighting key changes and noting where further information or materials may be forthcoming from the Fed.
TALF 2020 And CLOs
To print this article, all you need is to be registered or login on Mondaq.com. 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 are not rated below AAA by any other rating agency will be eligible collateral for loans under the TALF 2020 program.
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 employees or $5 billion in 2019 annual revenue (previously up to 10,000 employees or $2.5 billion in 2019 annual revenue). The minimum size of certain loans was also reduced to $500,000 from $1 million to help provide assistance to smaller businesses.
Html.Raw(The CARES Act And CLOs - Coronavirus (COVID-19) - United States)
To print this article, all you need is to be registered or login on Mondaq.com. On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act,1 was signed into law.
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 are not rated below AAA by any other rating agency will be eligible collateral for loans under this program. In this Legal Update, we highlight several aspects of the preliminary terms of TALF 2020 with particular relevance to CLOs.
The CARES Act and CLOs | JD Supra
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act,1 was signed into law.
Legal Update on Section 4003 of the CARES Act – Liquidity for Eligible Businesses, States, and Municipalities | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
The CARES Act and CLOs
As discussed in a previous post, Section 4003 of the Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act, authorizes $500 billion of liquidity to support businesses, states and municipalities “related to losses incurred as a result of coronavirus.” It can be expected that a portion of the liquidity authorized by Section 4003 of the CARES Act will take the form of loans to companies that are borrowers under loans held by collateralized loan obligation vehicles (“CLOs”).
Legal Update on Section 4003 of the CARES Act – Liquidity for Eligible Businesses, States, and Municipalities | LexBlog
In a development with potential relevance for leveraged borrowers and, by extension, the CLO market, the Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act, was signed into law by President Trump on March 27, 2020. The CARES Act provides for liquidity support for both large and mid-size businesses that, unlike the Primary Market Corporate Credit Facility and the Secondary Market Corporate Credit Facility, is not limited to investment grade businesses or investment grade debt.
Potential Volcker Rule Changes Announced
On January 30, 2020, five federal financial regulatory agencies published the long awaited notice of proposed rulemaking (the “NPR”) to revise certain aspects of the Volcker Rule (Section 13 of the Bank Holding Company Act) with respect to the treatment of covered funds. The NPR follows over 2 ½ years of the agencies’ consideration of changes to the Volcker Rule, which was originally prompted by the June 2017 Treasury Report that solicited changes to ease the compliance burden on banks.
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