At last count, we now have four separate risk retention regimes (maybe five) that we need (or will soon need) to deal with as we attempt to restructure any securitization. They are, of course, all different. And let’s be crystal clear. This isn’t an issue for the distant future. Risk retention is here now and … 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
With Thanksgiving approaching and the holiday season in full swing, we here at Crunched Credit would like to present our annual “Golden Turkeys”. The Golden Turkey for the Most Confounding Regulation: The Premium Capture Reserve Account Back in March, the credit risk retention NPR was released. Perhaps the most unexpected (and unwelcomed) part of the … Continue Reading
The Chairman of the House Committee on Financial Services (“HFSC”) Spencer Bachus (R-AL) and the Chairman of the HFSC Subcommittee on Capital Markets and GSEs Scott Garrett (R-NJ) submitted a letter on August 2, 2011 to the joint regulators addressing the premium capture cash reserve account (“PCCRA”) as proposed in the risk retention NPR. Under … Continue Reading
The process of transforming 2,000 pages of Dodd-Frank into 25,000 pages of regulations is well under way. Front and center is Risk Retention. I assume you, like me, have been studying the 300 plus pages of the proposed Risk Retention rules (known to the cognoscenti as the Risk Retention “NPR”) for the past several weeks … Continue Reading
On May 5, SIFMA hosted a Spotlight Series: Risk Retention and Qualified Residential Mortgages. It was immediately apparent that unintended consequences of the proposed risk retention rules (pdf) abound. The panelists acknowledged that the regulators had a very tough mandate, and that the rules are way more complicated than anticipated. It was estimated that approximately … Continue Reading
