On October 30, 2019, SEC Chairman Jay Clayton announced that the SEC will review its RMBS asset-level disclosure requirements with “an eye toward facilitating SEC-registered offerings.”   The announcement notes the absence of SEC-registered RMBS securitizations in recent years and seeks input from investors, issuers and other market participants with respect to several questions posed in the announcement, including questions about the RMBS market, the asset-level disclosure requirements for RMBS, and the market practice of providing…

In July, the Federal Deposit Insurance Corporation (the “FDIC”) proposed a change (discussed here and here) to certain provisions of its securitization safe harbor rule (the “Rule”) to eliminate the requirement that the securitization documents for non-grandfathered bank-sponsored securitizations not otherwise subject to Regulation AB (i.e. non-public transactions) require compliance with the disclosure and periodic reporting requirements of Regulation AB.   If adopted in its proposed form, this would significantly ease the compliance burden associated…

The European Commission (the “Commission”) has now adopted and published the regulatory technical standards (the “RTS”) in relation to the transparency requirements under the EU Securitisation Regulation (the “Securitisation Regulation”). The Securitisation Regulation has been applicable since 1 January 2019 to all securitisations (as defined therein) other than securitisations existing prior to that date to the extent that they are grandfathered. Article 7 of the Securitisation Regulation sets out transparency requirements (the “Article 7 Requirements”)…

On 22 October 2019, Mayer Brown’s supply chain and working capital finance team hosted its annual Supply Chain and Working Capital Finance seminar in London.  Now in its third year, the seminar brought together key members of Mayer Brown’s supply chain and working capital finance team from around the world as well as over 100 outside guests for a day-long programme to review recent trends and developments in the dynamic supply chain and working capital…

On October 15th, Mayer Brown’s supply chain finance team hosted its annual Supply Chain and Working Capital Finance seminar in New York.  Now in its fifth year, the seminar brought together key members of Mayer Brown’s supply chain team from around the world as well as over 250 outside guests for a day-long program to review recent trends and developments in the dynamic supply chain finance market.   Topics covered included risk distribution, dealing with alternative…

The European Banking Authority (the “EBA”) has recently launched a public consultation on its proposals to create a simple, transparent and standardised (“STS”) framework for synthetic securitisations, as set out in its Draft Report on STS Framework for Synthetic Securitisation published on 24 September 2019 (the “Discussion Paper”), which can be found here.  While the Securitisation Regulation allows traditional securitisations to benefit from preferential regulatory capital treatment if they meet the applicable STS criteria,…

The European Commission (the “Commission”) has now adopted and published the draft regulatory technical standards (the “Draft RTS”) in relation to the transparency requirements under the EU Securitisation Regulation (the “Securitisation Regulation”).  The Draft RTS are based on the draft regulatory technical standards published by the European Securities and Markets Authority on 31 January 2019 (the “ESMA Draft RTS”) and set out the information to be provided with respect to the underlying exposures in a…