Cadwalader, Dechert, Orrick and Sidley attorneys distributed a Q&A on risk retention for commercial mortgage-backed securities ("CMBS"). The Q&A is intended to facilitate the implementation of a joint final rule on the credit risk retention requirements of Securities Exchange Act Section 15G. The joint final rule was adopted by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve, the FDIC, the SEC, the Federal Housing Finance Agency and the Department of Housing and Urban Development (collectively, the "Agencies") on December 24, 2014.
The attorneys noted that the views expressed in the Q&A do not constitute legal advice, have not been informed by formal or informal guidance provided by the Agencies, and do not reflect the views of all CMBS market participants. The answers in the document reflect the attorneys' belief as legal participants that the positions presented in response to the questions posed are appropriate. The attorneys also explained that views presented in the Q&A may change as market practices develop and/or if additional guidance from the Agencies becomes available.
Click here to view the Q&A in the Cadwalader Client & Friends Alert authored by Michael Gambro and Jeffrey Rotblat, among others.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
