• Fallout from Dodd-Frank: Foreign Banks Sponsoring ABCP Conduits May Need to Register as Investment Advisers
  • November 8, 2010
  • Law Firm: Kaye Scholer LLP - New York Office
  • One of the many federal laws affected by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) signed by President Obama on July 21, 2010 is the Investment Advisers Act of 1940 (the “IAA”). Thus far, the amendments to the IAA have not received much attention from the securitization industry, but the amendments do impose new registration and compliance requirements on certain participants in securitization transactions. In particular, foreign banks that sponsor ABCP conduits may be surprised to learn that they will become subject to these new requirements.