Last week we reported that the Government Accountability Office (“GAO”) issued an opinion that the Leveraged Lending Guidance (“LLG”) was a “rule” subject to the Congressional Review Act (“CRA”) and explained how that ruling could have profound implications for the loan market.
In a step that could have far reaching implications for the loan market, on Thursday, the Government Accountability Office (“GAO”) issued an opinion that Leveraged Lending Guidance (“LLG”) issued jointly by the OCC, the Federal Reserve Board and the FDIC (the “Agencies”) is a “general statement of policy” and therefore considered a “rule” for purposes of the Congressional Review Act (“CRA”) and must be submitted to Congress for review. For the uninitiated, this could be big. Really big. The GAO’s decision is available here.
In case you missed it, there is potentially momentous – if Washington-centric – news on Leveraged Lending Guidance. Last Friday, Senator Toomey (R-PA) sent a letter to the Government Accountability Office (GAO) asking whether the Leveraged Lending Guidance actually was a “rule” in guidance’s clothing, Politico Pro and American Banker reported. Why does this matter? It could, theoretically, mean that Leveraged Lending Guidance is changed – or even goes away.
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Membership in the LSTA offers numerous benefits and opportunities. Chief among them is the opportunity to participate in the decision making process that ultimately establishes loan market standards, develops market practices, and influences the market’s direction.