The federal regulatory agencies responsible for implementing regulations under The Dodd-Frank Wall Street Reform and Consumer Protection Act finalized rules for risk retention requirements in CLO transactions (the “Final Rule”) on October 21-22, 2014.

As required by the Dodd-Frank Act, the Final Rule becomes effective with respect to CLOs two years after publication in the Federal Register. The final rules will be published in the Federal Register on December 24, 2014.2 Therefore compliance with the final rule will be required for CLOs beginning on December 24, 2016.