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Fed support for at least short term ABCP markets looks quite promising

By Matthew Bisanz, Carol A. Hitselberger, J. Bradley Keck, Arthur S. Rublin & Jeffrey P. Taft on March 25, 2020
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The disruptions in economic conditions caused by the coronavirus disease 2019 (COVID-19) are reaching the commercial paper and longer term debt capital  markets.  The Board of Governors of the Federal Reserve System (Federal Reserve) has already set into motion three separate facilities as part of its effort to facilitate credit and help alleviate collateral volatility that are expressly available to different participants in such.  On March 17, 2020,  the Federal Reserve reestablished a dealer credit facility last operated during the 2008 credit crisis. The Primary Dealer Credit Facility (“PDCF2020”) is a loan facility that provides credit to primary dealers, secured by certain highly rated fixed income collateral.  The Commercial Paper Funding Facility also was reintroduced on March 17, 2020 (“CPFF2020”).

CPFF2020 mirrors the commercial paper funding facility commenced by the Federal Reserve in 2008 and is available to eligible ABCP issuers that apply for it and pay a facility fee.  Issuers participating in the CPFF2020 will have direct access to the Federal Reserve for backstop purchases of their ABCP at predetermined rates irrespective of then current market conditions.  On March 18, 2020, the Federal Reserve established a separate facility (the Money Market Mutual Fund Liquidity Facility, or “MMLF”) that is designed to provide liquidity to certain types of money market mutual funds (“MMFs”).  MMLF is intended to support prime, state and municipal MMFs that experience significant stress in the event that investors seek to redeem their MMF shares for cash.  MMLF provides for the Federal Reserve to make loans to eligible financial institutions that purchase certain eligible assets from MMFs.

Photo of J. Bradley Keck J. Bradley Keck
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Photo of Jeffrey P. Taft Jeffrey P. Taft

Jeffrey Taft is a partner in the Firm’s Financial Services Regulatory & Enforcement group and the Cybersecurity and Data Privacy practice. His practice focuses primarily on bank regulation, bank receivership and insolvency issues, payment systems, consumer financial services and cybersecurity/privacy issues. He has…

Jeffrey Taft is a partner in the Firm’s Financial Services Regulatory & Enforcement group and the Cybersecurity and Data Privacy practice. His practice focuses primarily on bank regulation, bank receivership and insolvency issues, payment systems, consumer financial services and cybersecurity/privacy issues. He has extensive experience counseling financial institutions, merchants, technology companies and other entities on various federal and state banking and consumer credit issues, including compliance with the Bank Holding Company Act, National Bank Act, International Banking Act, Consumer Financial Protection Act, Truth-in-Lending Act, the Fair Credit Reporting Act, the Electronic Fund Transfer Act, the Equal Credit Opportunity Act, the Fair Debt Collection Practices Act, the Real Estate Settlement Procedures Act, state unfair or deceptive acts or practices statutes, CFPB’s UDAAP authority and the development and implementation of privacy, cybersecurity and information security programs under the Gramm-Leach Bliley Act, the NYDFS cybersecurity regulation and industry standards, such as PCI DSS and NIST.

Read Jeff’s full bio.

Read more about Jeffrey P. TaftEmail
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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Retained Interest
  • Organization:
    Mayer Brown

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