June 9, 2020 - On Monday, June 8th, The Federal Reserve Bank of NY issued revisions to the FAQs: TALF originally issued on May 12, 2020. The LSTA held a webcast TALF & CLOs: Take Two Presentation where we and our panelists noted a number of hurdles that would need to be overcome if there were to be significant uptake of the program. One of those hurdles prohibited the pledge of ABS (including CLO-AAA’s) that is redeemable within three-years of issuance. Updated FAQs reduce that redemption provision to after one-year of issuance which is in line with market standards for static CLOs. The updated FAQs included a number of other minor clarifications, but none of these addressed issues that would make the TALF remarkably attractive to investors or managers.

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Market Advisory on FIRPTA

The LSTA published a Market Advisory which discusses the implications of The Foreign Investment in Real Property Tax Act (“FIRPTA”).