We thought it would be useful to give a quick, interim update on the slow-motion train wreck that is our industry’s response to the upcoming effectiveness of the Risk Retention Rule. For those of you who have been blessedly snoozing under a rock these past couple of years, the Risk Retention Rule becomes effective on … Continue Reading
As we begin to close in on the initial implementation of the Risk Retention Rule, we are looking beyond the headlines and trying to figure out how the Rule will actually work. The result is troubling.… Continue Reading
Last week, we and a few of our colleagues here at Dechert attended CREFC’s 2013 Distressed Debt Summit. Echoing the mood at January’s CREFC conference, the mood at the NY Athletic Club last week was upbeat about the CMBS market as a whole but the general sentiment, with respect to the distressed debt market, is … Continue Reading
Two and a half years after Dodd-Frank and almost two years after the first hurriedly issued proposed rules, the six agencies (Department of Housing and Urban Development, Federal Deposit Insurance Corp., Federal Housing Finance Agency, Federal Reserve, Office of the Comptroller of the Currency, and the U.S. Securities and Exchange Commission) charged with creating risk retention … Continue Reading
Back from vacation … The sheer joy of re-engagement cannot be captured in words. But, can there be a better way of restarting than perusing FinReg? Being the parochial structured finance lawyer that I am, I start with Subtitle D with the Potemkin village-like name of "Improvements to the Asset Backed Securitization Process" and Section … Continue Reading
This article was published by Matthew T. Clark and Stewart McQueen. The 2010 CREFC Annual Convention has begun in earnest. Day 1 began for many attendees with a meeting of the Securities and Loan Investors Forum. This meeting included a lengthy discussion of the Fair Value Purchase Option and a perceived conflict of interest existing when … Continue Reading
I can’t stand it. We now have skin in the game provisions proposed by the SEC, the FDIC, the House of Representatives and the United States Senate. On CNN the other day, Congressman Barney Frank said that the most important part of the House Financial Reform bill was skin in the game in securitization. Okay, I know we’re probably … Continue Reading
The Wall Street Journal and Bloomberg, among other outlets, reported last week that the Royal Bank of Scotland Group Plc is in the process of placing a multi-borrower securitization – the first such issuance to come to market since June 2008. Of course, RBS is facing several hurdles as it trailblazes once-familiar territory. The offering, variously reported … Continue Reading
I’m just about to do another CRE Finance Council (formerly CMSA) PSA after work tutorial. A couple of observations. As a lawyer who packed the sausage casings, it is startling to see how much uncertainty and, in fact, misinformation exists about how a PSA actually works in the community of people who buy and sell bonds and other financial assets. Perhaps not … Continue Reading
