Congress passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) this afternoon, and we cover it here in two memos. In one memo, we cover the economic stabilization, small business and bank regulatory sections of the legislation. In the other memo, we cover tax…
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The Federal Reserve has issued updated FAQs regarding its money market mutual fund liquidity facility (MMLF), modifying the FAQs issued on March 21.

For more information on the MMLF, please see our memorandum and blog post describing the original MMLF announced on March 18, our blog post describing…
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The CFTC unanimously approved final interpretive guidance describing what constitutes “actual delivery” of a virtual currency for purposes of the actual delivery exception from the provisions of the Commodity Exchange Act that prohibit any leveraged, margined, or financed transaction in a commodity with a retail customer, unless the transaction is…
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The Federal Reserve has issued FAQs providing more information about its Commercial Paper Funding Facility (CPFF), originally announced on March 17, 2020 and expanded on March 23, 2020 as part of its response to the coronavirus crisis.  The FAQs provide additional details on how the CPFF will work,…
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Following our initial post on the Bank of England’s (the “Bank”) Covid Corporate Financing Facility (“CCFF”), the Bank has published further details, including full terms and conditions of participation and application forms for prospective issuers and banks acting on behalf of companies.

If, after speaking with their respective banks, prospective…
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The Federal Reserve announced on March 23, 2020 further action in response to the coronavirus crisis: the creation of the Secondary Market Corporate Credit Facility (SMCCF), along with establishment of the Primary Market Corporate Credit Facility (PMCCF) and the Term Asset-Backed Securities Loan Facility (TALF). We discuss the…
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The Federal Reserve announced on March 23, 2020 further action in response to the coronavirus crisis: the creation of the Primary Market Corporate Credit Facility (PMCCF), along with the Secondary Market Corporate Credit Facility (SMCCF) and the Term Asset-Backed Securities Loan Facility (TALF). We discuss the SMCCF and…
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Here is Davis Polk’s two-page overview of the Federal Reserve’s actions to address the coronavirus crisis, with embedded links to the primary materials on the Federal Reserve’s website. This version is updated to cover the new, sweeping measures that the Fed announced on the morning of Monday, March 23, 2020.  …
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The Federal Reserve announced a further expansion of the Money Market Mutual Fund Liquidity Facility (MMLF), originally announced on March 18, 2020 and expanded on March 20, 2020, as part of its response to the coronavirus crisis.  Under the further expanded MMLF, additional securities are eligible as collateral.…
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