• Credit Risk Retention: Six Federal Agencies Repropose Joint Rules on Credit Risk Retention
  • October 7, 2013
  • Law Firm: Sullivan Cromwell LLP - New York Office
  • On August 28, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Securities and Exchange Commission (“SEC”), the Federal Housing Finance Agency (“FHFA”) and the Department of Housing and Urban Development (“HUD” and, collectively, the “Agencies”) issued a second Notice of Proposed Rulemaking (the “revised proposal”) to implement the credit risk retention requirements of Section 941 of the Dodd-Frank Act. Our April 21, 2011 memorandum entitled “Credit Risk Retention: Six Federal Agencies Propose Joint Rules on Credit Risk Retention for Asset-Back Securities” describes Section 941 and the original proposal, which was issued in 2011 (the “original proposal”). The deadline for public comment on the revised proposal is October 30, 2013.