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Disclosure Requirements under the Securitisation Regulation Delayed: Application of CRA3 Transitional Provisions

United Kingdom, European Union - December 3 2018 The EU Securitisation Regulation (the "Securitisation Regulation") will come into effect on 1 January 2019, bringing a number of changes to the...

Catherine Leef Martin, James Warbey, John Goldfinch.

SEC No-Action Letter Grants Relief to Middle MarketBalance Sheet CLO Manager and External Adviser to BDCs, Permitting Transfer of 100 of Risk Retention Interest to BDCs

USA, United Kingdom - September 20 2018 On September 7, 2018, the staff of the Division of Investment Management of the SEC (the "Staff") issued a no-action...

Andrew Keller.

D.C. Circuit Rules Managers of Open-Market CLOs Are Not Required to Have “Skin in the Game”

USA - February 13 2018 A three-judge panel of the U.S. Court of Appeals for the D.C. Circuit ("D.C. Circuit") issued a unanimous decision1 on Friday, February 9, 2018...

Catherine Leef Martin, Ashley Whang, Jay D. Grushkin, Nicholas Robinson, James Warbey.

Madden v. Midland Funding LLC implications and potential responses

USA - October 8 2015 This client alert focuses on the implications of the Second Circuit’s Decision in Madden v. Midland Funding, LLC (“Madden”) and Considers strategies...

Albert A. Pisa, Robert C. Hora, Douglas Landy.

SEC staff grants limited relief from compliance with US risk retention rules in the context of certain CLO refinancings

USA - July 29 2015 On July 17, 2015, the SEC staff (the "Staff") issued a no-action letter (the "Letter") granting limited relief from compliance with the risk...

Sean Garcia.