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Crucial Transitional Relief under the FDIC Securitization Safe Harbor
Carol A. Hitselberger, Jason H. P. Kravitt, Jeffrey P. Taft, November 18, 2009
On November 12, 2009, the Board of the FDIC approved an interim rule that provides some crucial transitional relief relating to recent changes in US accounting standards for securitizations...One of the key impacts of the accounting changes is that banks (among other entities) will no longer be...

IRS Chief Counsel Memorandum on Effectively Connected Income if Loan Origination Activity is conducted through a U.S. Agent
James R. Barry, Jason S. Bazar, Russell E. Nance, Daniel R. Read, October 1, 2009
On September 22, 2009, the Office of Chief Counsel of the Internal Revenue Service (the "Service") issued a memorandum to the Director of Field Operations for Financial Services in Manhattan (the "Memorandum") setting forth its position and legal analysis with respect to certain...

OTC Derivatives--In the Crosshairs of US Legislative and Regulatory Change Part III: An Update
J. Paul Forrester, Jamila A. Piracci, Jerome J. Roche, David R. Sahr, September 16, 2009
We have previously written about legislative and regulatory developments facing the over-the-counter (OTC) derivatives market. These development include a number of bills introduced in Congress as well as the framework outlined by the Department of the Treasury in the June white paper,...

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