This comment letter was submitted to the Japanese Financial Services Agency on its recent proposal that would impose significantly higher capital charges on Japanese investors who purchase interests in certain securitizations that are not risk retention compliant....
The LSTA submitted a comment letter on proposed changes to the Volcker Rule. Importantly for the loan and CLO markets, the proposal puts into play the issue of whether banks can own the debt securities of CLOs that hold bonds. The LSTA’s comment letter focuses on two points. First, it suggests that the final rule’s...
The Securities and Exchange Commission earlier this year issued a two-part release that could impact investment managers - including loan managers. The second part of the release requests comments regarding proposed enhanced investment adviser regulation. The LSTA this week submitted a comment letter on the two proposals, broadly supporting the recommendations of the Investment Advisers...
On LIBOR: LSTA Comment Letter October 31, 2017 (article updated on November 2, 2017) - On October 30, 2017, the LSTA, along with a number of other trade associations, submitted a comment letter in response to the Federal Reserve’s “Request for Information Relating to the Production of Rates”. Behind that unprepossessing title is one of...
In response to the “Request for Information Relating to the Production of Rates”, the LSTA submitted a letter to the Federal Reserve discussing the impact of a transition from LIBOR to SOFR (or another reference rate) on the U.S. syndicated loan market. The letter discusses key stakeholders in the syndicated loan market and why they...
In response to a recent Executive Order from president Trump outlining “Core Principles” for financial regulation and seeking suggestions for streamlining financial regulation, the LSTA submitted a letter to Treasury Secretary Mnuchin. The letter outlines why the application of the Dodd-Frank risk retention provides no benefits but causes substantial harm to borrowers, investors, managers and,...
On Thursday August 18, 2016, the Loan Syndications and Trading Association (LSTA) submitted a comment letter to the OCC, Federal Reserve, FDIC, FHFA, NCUA and SEC in response to their notice of proposed rulemaking on Incentive-Based Compensation Arrangements....
On Tuesday, July 20, 2016, the Loan Syndications and Trading Association (LSTA) submitted a comment letter to European Parliament’s ECON Rapporteur Paul Tang in response to proposed amendments to “Simple, Transparent and Standardised (STS)” Securitizations....
On Wednesday, January 13, 2016, the Loan Syndications and Trading Association (LSTA) submitted a comment letter to the SEC in response to the proposed rule on Open-End Fund Liquidity Risk Management Programs....
The LSTA submitted a comment letter to the EBA arguing that CLOs performed well in the crisis, that they have none of the characteristics identified as likely to create difficulties during periods of turmoil, and explaining that Qualified CLOs align with the principles of simple, standard and transparent securitizations....
