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Syndicated Loan Market Advocacy & Regulatory

The LSTA advocates on behalf of the loan market, and focuses on critical matters (regulations under Dodd-Frank, Leveraged Lending Guidance, FATCA and Bankruptcy reform) that could dramatically affect the loan market and the broader economy.

FATCA

Displaying 1-8 of 8 results.
DateTitle/DescriptionFiles
Mar 24, 2014

LSTA Letter Requesting Changes to the Definition of Limited Life Debt Investment Entity

LSTA submitted a letter to the IRS and Treasury requesting changes to the definition of “limited life debt investment entity” in the temporary regulations implementing FATCA issued by the IRS in February 2014.

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Feb 20, 2014

Risk Retention and CLO Overview: Two Steps Forward, One Step Back

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Sep 6, 2013

LSTA Submits Letter to IRS and Treasury on FATCA Compliance by CLOs

LSTA submitted a letter to the IRS and Treasury supporting the letter submitted by ISDA on August 28, 2013 as it pertains to FATCA’s reporting requirements for CLOs.

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Apr 17, 2013

LSTA/SIFMA Joint Letter Re Proposed Definition of “Limited Life Debt Investment Entity” in FATCA

LSTA and SIFMA jointly submitted a letter to the IRS and Treasury requesting technical corrections to their definition of “Limited Life Debt Investment Entity” in the FATCA proposal.

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Apr 30, 2012

LSTA Issues Fourth Comment Letter on FATCA

The LSTA submitted its fourth comment letter in response of the IRS’s proposed regulations implementing FATCA released on February 8, 2012.

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Jun 7, 2011

Third LSTA Comment Letter on FATCA

LSTA submitted a third comment letter to the IRS and Treasury in response to Notice 2011-34 and a meeting with IRS staff members.

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Nov 1, 2010

Second LSTA Comment Letter on FATCA

LSTA submitted a second comment letter to the IRS on FATCA, focusing on the implications for the CLO market.

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Jul 15, 2010

Original LSTA Comment Letter on FATCA

LSTA submitted its initial comments to the IRS and U.S. Department of the Treasury on the implications for the proposed FATCA rules on the U.S. corporate loan market.

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Leveraged Lending Guidance

Displaying 1-12 of 12 results.
DateTitle/DescriptionFiles
Mar 6, 2018

Leveraged Lending Guidance: Rumors of its Death

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Jan 24, 2018

Leveraged Lending Guidance: What’s Next?

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Dec 13, 2017

Leveraged Lending Guidance: Regulators Respond

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Aug 2, 2017

SNC Review

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Aug 2, 2017

SNC Programs

Exhibit 4, Page 6

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Jun 13, 2014

Leveraged Lending Guidance and SNC

Regulators are working on the first SNC reviews following the full implementation of the Leveraged Lending Guidance (LLG).  Recent press stories ask whether LLG are impacting loan terms – and whether the SNC exams will affect behavior.

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May 16, 2014

Leveraged Lending: Recovery and Warning Shots

Since 2013, the OCC has been vocal in its advocacy of the Leveraged Lending Guidance. In recent months, the Federal Reserve has become vocal as well.

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Feb 20, 2014

Overview

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Apr 11, 2013

LSTA and ABA ask OCC, FDIC and Federal Reserve for 12 months to implement Leveraged Lending Guidance

LSTA and ABA ask OCC, FDIC and Federal Reserve for 12 months to implement Leveraged Lending Guidance.

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Mar 21, 2013

The LSTA Appreciates Bank Agencies’ Decision to Refine Leveraged Lending Guidance in Key Areas: Remains Concerned About ‘One Size Fits All’ Approach

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Aug 21, 2012

Joint Additional Comment Letter

At the request of the banking agencies, the LSTA and ABA submit an additional comment letter explaining why fallen angels should not be included in the leveraged lending guidance.

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Jun 8, 2012

Joint Comment Letter on Leveraged Lending Guidance

The LSTA and ABA submit comment letter on leveraged lending guidance.

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Risk Retention

Displaying 1-24 of 24 results.
DateTitle/DescriptionFiles
Apr 5, 2018

District Court Vacates the Rule

District Court Order

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Apr 3, 2018

CLO Risk Retention Timeline & Appeals Scenarios

Which walks through the Legislative, Regulatory and Legal efforts

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Mar 27, 2018

Risk Retention Litigation: The Government Stands Down (At Least for Now)

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Feb 28, 2018

Risk Retention: A Chorus from the Aria

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Feb 27, 2018

CLO Risk Retention: Does Everything Change After US Court of Appeals Ruling?

Presentation that Meredith Coffey did for Structured Finance Industry Group (SFIG) conference in Vegas.

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Feb 21, 2018

Open Market CLO Credit Risk Retention Decision - Next Steps

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Feb 15, 2018

CLO Risk Retention Ruling: Analysis From the Trenches

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Feb 12, 2018

Risk Retention Goes On Vacation

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Feb 9, 2018

Court Opinion

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Jan 26, 2018

Risk Retention Litigation: The Uncertainty Principle

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Jul 12, 2017

Reply Brief

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Apr 19, 2017

Opening Brief to the DC Circuit Court of Appeals

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Jun 25, 2014

LSTA Submits Letter to U.S. Regulators that Highlights Parallels Between “Qualifying Securitizations” and Qualified CLOs

The Loan Syndications and Trading Association (LSTA) submitted a letter to U.S. regulators that highlights “qualifying securitizations” in light of the implementation of risk retention for collateralized loan obligations (CLOs) under Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

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May 26, 2014

Meredith Coffey Testifies Dodd-Frank Act’s Impact on Asset-Backed Securities

Testimony of LSTA EVP Meredith Coffey on the Volcker Rule and Risk Retention before the House Financial Services Subcommittee on Capital Markets.

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Feb 20, 2014

Risk Retention and CLO Overview: Two Steps Forward, One Step Back

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Jan 10, 2014

LSTA Files Comment Letter on Dodd Frank's Risk Retention Requirement.

The LSTA, SIFMA and SFIG proposes the “Qualified CLO”, whereby a CLO that meets six strict criteria can meet the risk retention requirement by retaining 5% of equity, not 5% of the notional amount of a new CLO.

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Nov 18, 2013

LSTA Releases Oliver Wyman Study That Urges Caution on Regulations on Collateralized Loan Obligations

Oliver Wyman Study on Risk Retention and CLOs: This study estimates the probable impact of risk retention on CLOs, and the subsequent reduction in availability of credit and increased cost of credit for non-Investment grade U.S. borrowers.

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Oct 30, 2013

LSTA Submits Risk Retention Re-Proposal Comment Letter

The LSTA responds to the Agencies’ Risk Retention Reproposal, dated August 28, 2013.

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Jul 29, 2013

LSTA Submits Comment Letter to Joint Regulators

The LSTA provides the Agencies the results of a survey of CLO managers that determined their ability and willingness to retain risk.

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Apr 1, 2013

LSTA Offers New Risk Retention Plan for CLO’s Current Proposals Threaten to Shutter the Market

The LSTA proposes to the Agencies the concept of a “Modified L-Shaped Risk Retention Structure” for CLOs.

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Mar 9, 2012

CLO Regulatory Text Submission

The LSTA submits final proposed regulatory text exempting from risk retention an Open Market CLO that meets a number of criteria.

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Sep 1, 2011

LSTA Submits Final Proposed Regulatory Text

The LSTA submits final proposed regulatory text exempting from risk retention an Open Market CLO that meets a number of criteria.

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Aug 1, 2011

LSTA Submits Comment Letter on Risk Retention Requirements to Joint Regulators

The LSTA responds to the Agencies’ initial Risk Retention Proposal, dated April 29, 2011.

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Apr 12, 2011

LSTA's Bram Smith Testifies Risk Retention Proposals Don't Fit CLO Structures; Rules Threaten Vital Credit Source and US Jobs

The Executive Director of LSTA, Bram Smith, today testified before the House Subcommittee on Capital Markets.

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Volcker Rule

Displaying 1-11 of 11 results.
DateTitle/DescriptionFiles
Jun 13, 2014

Volcker Rule Implementation Guidance

The OCC published its Volcker Rule Interim Examination Procedures recently, which are structured to help examiners determine whether banks have business activities subject to Volcker – and if banks are implementing plans to comply.

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Jun 13, 2014

“Volckerizing” Legacy CLOs

Banks are working with the trade associations to develop a draft template to facilitate amendments to remove bond baskets from legacy CLOs, thus “Volckerizing” them.

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Apr 7, 2014

LSTA Responds to Fed Announcement of Treatment of CLOs Under Volcker Rule

Reaction to the announcement by the Federal Reserve Board that it will issue a two-year extension of the conformance period under the Volcker Rule for debt securities issued by collateralized loan obligations (CLOs).

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Feb 26, 2014

Complete Testimony of Meredith Coffey, LSTA EVP, Research & Analysis

Meredith Coffey Testified at a hearing of the House Financial Services Committee on Dodd-Frank Act’s Impact on Asset-Backed Securities.  

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Feb 20, 2014

Overview

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Jan 15, 2014

Complete Testimony of LSTA General Counsel Elliot Ganz

Elliot Ganz, testified at a hearing before the House of Representatives’ Financial Services Committee entitled, “The Impact of the Volcker Rule on Job Creators, Part I”.

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Jan 10, 2014

LSTA Files Third Comment Letter on Final Volcker Rule

The LSTA filed a third comment letter on the Final Volcker Rule clarifying certain aspects of the December 24th and December 31st letters.

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Dec 31, 2013

LSTA Files Second Comment Letter on Final Volcker Rule

The LSTA filed a second letter to the regulatory agencies again requesting confirmation that the term “ownership interest” in the Final Volcker Rule does not include debt securities of CLOs and asking for expedited relief.

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Dec 24, 2013

LSTA Seeks Clarification of “Ownership Interest” Under Volcker

The LSTA submitted a letter to the regulatory agencies seeking clarification that “ownership interest” in the Final Volcker Rule does not include debt securities of CLOs.

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Feb 13, 2012

LSTA Submits Comment Letter on Volcker Rule Proposal

The LSTA filed a comment letter on the proposed regulations implementing the Volcker Rule urging the regulatory agencies to exclude CLOs from the Volcker Rule.

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Nov 5, 2010

LSTA Urges FSOC not to extend “Volcker Rule” to Syndicated Loans

LSTA submitted a letter to the Financial Stability Oversight Council not to extend the Volcker Rule’s prohibitions on proprietary trading to commercial loans.

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LIBOR

Displaying 1-36 of 36 results.
DateTitle/DescriptionFiles
Nov 8, 2018

LIBOR Consultation Extended! Corporates Engaged?

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Nov 6, 2018

ARRC Consultation Deadline Extended to November 26th

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Oct 30, 2018

ARRC Consultation: Spotlight on the Amendment Approach

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Oct 18, 2018

LIBOR: Hardwiring A Better Future?

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Oct 17, 2018

Vice Chairman Quarles on LIBOR: Be Prepared

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Oct 11, 2018

LIBOR Transition: Trigger Warnings (!)

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Sep 26, 2018

Loan Consultation Explanation

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Sep 25, 2018

LIBOR Fallback (Consultations) Are Here!

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Sep 6, 2018

LIBOR: Almost Time to Fallback?

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Aug 1, 2018

SOFR: Terms of Endearment

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Jul 24, 2018

LIBOR: Revelations of the ARRC

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Jul 18, 2018

LIBOR: What Lies Beneath

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Jul 17, 2018

ARRC Guiding Principles

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Jul 10, 2018

LIBOR Fallbacks: What to Expect When You’re Expecting SOFR

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Jun 26, 2018

Survey Says: LIBOR Transition Daunting, But Doable

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Jun 20, 2018

LIBOR: Illuminating the Path Foward?

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Jun 20, 2018

LIBOR: Moody Blues

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May 31, 2018

LIBOR Fallbacks: A Snapshot of Syndicated Loans

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May 31, 2018

LIBOR: Five Easy Pieces?

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May 30, 2018

LIBOR FAQs

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May 30, 2018

LIBOR and the Loan Market: An Update - Presentation

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May 1, 2018

LIBOR in Chicago

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Apr 25, 2018

LIBOR, Loans and Ops

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Apr 12, 2018

SOFR Away From Me?

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Mar 27, 2018

LSTA Statement on LIBOR Replacement

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Mar 22, 2018

LIBOR OIS

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Mar 22, 2018

“End-of-LIBOR” Debate

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Nov 28, 2017

LIBOR Banks Are Here to Stay...For Now

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Oct 31, 2017

On LIBOR: LSTA Comment Letter

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Oct 19, 2017

LIBOR & Loans

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Sep 7, 2017

LIBOR Update: One Small Step for SOFR

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Aug 24, 2017

LIBOR: A Process, Not a Problem (II)

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Aug 17, 2017

LIBOR: Why You Should Care...And Shouldn't Panic

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Aug 3, 2017

LIBOR (Transition) in the Loan Market

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Jul 27, 2017

LIBOR Redux

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Jul 20, 2017

LIBOR Going Away? Not So Fast

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