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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Ledina Gocaj
Fed Establishes the Primary Market Corporate Credit Facility to Support Credit to Employers
By John Banes, Luigi L. De Ghenghi, Randall D. Guynn, Margaret E. Tahyar, Ledina Gocaj, Carol Rodrigues & Andrew Samuel on
Posted in Coronavirus (COVID-19), Federal Reserve
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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Client Memorandum: FDIC Proposes Supervision of ILC Holding Companies
The FDIC proposed a rule to formalize certain longstanding expectations it has for approving applications by new industrial loan companies (ILCs) that would be subsidiaries of a parent company that would not be subject to consolidated supervision by the Federal Reserve. The proposal would require a written agreement…
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Davis Polk Client Memorandum: Agencies Extend Volcker Rule Relief for Qualifying Foreign Excluded Funds
Posted in Volcker Rule
As widely expected, the Volcker Agencies extended relief from the Volcker Rule that was first granted to eligible foreign funds in 2017. The agencies’ action provides that the proprietary trading and covered fund prohibitions of the Volcker Rule do not apply: (1) to a foreign banking entity for activities or…
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