On Friday, the United States Office of the Comptroller of the Currency (“OCC”) finalized a regulation regarding the “Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred” by national banks and federal savings associations. Initially proposed in November
Retained Interest
An Analysis of Structured Finance, Financial Assets and Related Topics
The Mayer Brown blog covers a broad spectrum of legal topics with a focus on financial services, banking and finance, lending, and private credit. It provides analysis and updates on regulatory developments, litigation, and transactional issues affecting sectors such as capital markets, corporate and securities law, cybersecurity and data privacy, and international trade. The blog also addresses industry-specific matters including fintech, insurance, private equity, and infrastructure projects. Mayer Brown's insights include discussions on legislative changes, compliance requirements, and risk management strategies relevant to financial institutions, corporations, and investors globally.
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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…
Debt Collection During and After the Pandemic: Do Certain US Legislators and Agencies Seek a Debt Collection Ice Age?
On May 15, House Democrats passed on the Heroes Act, a $3 trillion package that revives, among other things, many of the severe debt collection-related restrictions House Democrats have been pushing since the start of the pandemic. Although the Heroes…
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…
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…
Federal Reserve Releases TALF FAQs: Here are the Highlights
On May 12, 2020, the Federal Reserve (Fed) published updates to the term sheet for the Term Asset-Backed Securities Loan Facility (the TALF), and FAQs regarding the TALF, including additional details regarding borrower and collateral eligibility.…
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…
PPPLF Now Open to Non-Banks and for Purchased PPP Loans
The Federal Reserve’s Paycheck Protection Program Liquidity Facility (“PPPLF”) is now available to non-bank PPP lenders to finance Paycheck Protection Program (“PPP”) loans that they originated or purchased. While the PPPLF was previously only available to depository institutions to finance…
Federal Reserve Signals Progress Toward Desperately Needed Non-Bank Access to Paycheck Protection Program Liquidity Facility (PPPLF)
Non-bank lenders providing struggling small businesses a lifeline through forgivable Paycheck Protection Program (“PPP”) loans may soon have access to the Federal Reserve’s Paycheck Protection Program Liquidity Facility (“PPPLF”) to support their lending operations. The Federal Reserve issued a term…
Recent Comments by US Treasury Secretary Mnuchin Should Give PPP Applicants Pause
In statements made yesterday on “Squawk Box” on CNBC, Secretary Mnuchin said:
“I’m going to be putting out an announcement later this morning that for any loan over $2 million, the Small Business Administration will be doing a full review…