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The Week in Review highlights this week's important
legal and regulatory developments affecting the financial
industry.
Featured in this week's edition:
Fed Issues Final Rule for Modified
Mortgage Loans
On November 13, the Fed and thrift
regulatory agencies issued a final rule providing that
mortgage loans modified under
HAMP will generally retain their
pre-modification risk weight. The final
rule modifies the interim final rule issued on June 20 by
clarifying that mortgage loans whose HAMP modifications
are in the trial period will also retain their
pre-modification risk weight. The final rule will take
effect 30 days after publication in the Federal Register,
which is expected shortly. Fed
Release. Final
Rule.
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Fed Rule Requires Notice to Borrowers of
Mortgage Loan Transfers
On November 16, the Fed issued an interim
final rule implementing the provision of the Helping
Families Save Their Homes Act of
2009 whereby creditors who purchase or are assigned
mortgage loans are required to notify the borrower of the
transfer and provide certain disclosure information. The
rule is effective immediately upon publication in the Federal
Register but compliance is optional for 60 days from
publication. Comments are requested within 60 days of
publication in the Federal Register. Fed
Release. Interim
Final Rule.
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TALF Updates
On November 13, the New York Fed issued
revised TALF documents,
FAQs, and Terms and Conditions.
The revised documents consist of: (i) the TALF Borrower
Eligibility and New York Fed Due Diligence Policy, (ii) the
Form of TALF-Specific Agreed-Upon Procedures Report, (iii) the
Conflicts of Interest Guidance for TALF Agents Participating
in TALF, and (iv) the Master Loan and Security
Agreement. Documents.
TALF
Borrower Eligibility (showing changes). TALF-Specific
Agreed-Upon Procedures (showing changes). Conflicts
of Interest Guidance (showing changes). MLSA.
MLSA
(showing changes). FAQs.
FAQs
(showing changes). Terms
and Conditions. Terms
and Conditions (showing changes).
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EU Credit Rating Agency Regulation
On November 17, the Official Journal of the EU
published a regulation on credit rating agencies
intended to guarantee additional protection for consumers
and investors by establishing a common regulatory
framework regarding the quality of credit ratings. The
Regulation sets forth credit rating conditions as well
as criteria governing the organization and management
of the credit rating agencies and applies to ratings by credit
rating agencies registered in the European Community and
published or broadcasted through subscription. The Regulation
will come into force on December 7. EU
Regulation.
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Rating Agency Criteria and Methodology Updates
On November 17, Moody's released its updated
guidelines for rating hybrid securities and
subordinated debt. Moody's
Report.
On November 16, Moody's released a request for
comment related to liquidity coverage in the Singapore
CMBS market. Comments are requested by December 16. Moody's
Report.
On November 18, Moody's updated its methodology for
rating Federal Family Educational Loan Program (FFELP)
student loans to include an additional assessment of the risk
posed by slow loan repayment rates. Moody's
Report.
Note: Free registration is required for all rating agency
releases and reports.
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