On Friday, December 5th, OCC and FDIC rescinded the 2013 Leveraged Lending Guidance and the 2014 FAQs that followed (collectively, “LLG”).
There’s no question but that Covid-19 was a massive stress test on the global financial system, not to mention the globe itself.
Leveraged Lending Guidance: Rumors of its Death March 6, 2018 - Is Leveraged Lending Guidance most likely to be 1) scrapped, 2) refined, or 3) unchanged? Folks reading reports from Comptroller Otting’s talk at SFIG Vegas may well select Option 1 (“scrapped”). However, Option 2 (“refined”) might the more probable answer. Below, we discuss what...
Exhibit 4, Page 6...
On March 31, 2017, Senator Pat Toomey (R-Pa.) sent a letter to the Comptroller General of the U.S. General Accounting Office (GAO) asking whether the Interagency Guidance on Leveraged Lending constitutes a “rule” for purposes of the Congressional Review Act (CRA). The CRA applies to agency “rules” (as defined in the CRA) and provides an...
An overview of the Leveraged Lending Guidance...
LSTA and ABA ask OCC, FDIC and Federal Reserve for 12 months to implement Leveraged Lending Guidance....
366 MADISON AVENUE NEW YORK, NY 10017 The LSTA Appreciates Bank Agencies’ Decision to Refine Leveraged Lending Guidance in Key Areas; Remains Concerned About ‘One Size Fits All’ Approach New York, NY – The Loan Syndications and Trading Association today ex- pressed appreciation for the decision by federal banking regulators, including the FDIC, Federal Reserve...
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....
The LSTA and ABA submit comment letter on leveraged lending guidance....

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