Dodd-Frank Weekly

by Winnie Lam, Esq.
On July 21, 2010, President Obama signed into law The Dodd‐Frank Wall Street Reform and Consumer Protection Act. Since then, the federal banking authorities have been promulgating rules in order to meet the various deadlines imposed by the Act. During this time, the general public and interested persons are participating in the process by submitting their comments to the authorities on the proposed rules. Amidst all this activity, Black Swan Consulting has kept abreast of the latest developments to see whether and how the Dodd‐Frank rules will affect its clients. Black Swan Consulting would like to share its findings on the rules most relevant to structured finance and its thoughts on the implications of the rule in a weekly series. Black Swan welcomes anyone with comments, thoughts, or ideas to join us in our discussion.
Week 1: Credit Risk Retention (Dodd-Frank Section 941)

In the first installment of our weekly series on the Dodd-Frank Act, we examine the scope of the Credit Risk Retention Requirements of Section 941 of the Dodd-Frank Act. Read more…

Week 2: Four Permissible Forms of Credit Risk Retention

In the second installment of our weekly series, we examine a segment of the Credit Risk Retention Requirement and discuss four permissible forms of credit risk retention under the proposed rule. Read more…

Week 3: Credit Risk Retention Option for Asset-Backed Commercial Paper Conduits

In the third installment of our weekly series, we examine an asset-type specific form of credit risk retention for asset backed commercial paper conduits. Read more…

Week 4: Credit Risk Retention Option for Commercial Mortgage-Backed Securities

In the fourth installment of our weekly series, we examine the asset-type specific form of credit risk retention for commercial mortgage-backed securities. Read more…

Week 5: Treatment of GSEs Under the Proposed Credit Risk Retention Rules

In the fifth installment of our weekly series, we examine the treatment of government-sponsored enterprises under the proposed credit risk retention rules. Read more…

Week 6: Premium Capture Cash Reserve Account

In the sixth installment of our weekly series, we examine the premium capture cash reserve account under the proposed rules. Read more…

Week 7: Allocation to the Originator

In the seventh installment of our weekly series, we discuss the option to allocate risk retention to the originator and the hedging, transfer, and financing restrictions under the proposed rules. Read more…

Week 8: Introduction to Qualified Residential Mortgages

In the eighth installment of our weekly series, we discuss the overall approach taken by the Agencies in defining qualified residential mortgages and their treatment under the proposed credit risk retention rules. Read more…

Week 9: Eligibility Criteria for Qualified Residential Mortgages

In the ninth installment of our weekly series, we examine the eligibility criteria for qualified residential mortgages under the proposed credit risk retention rules. Read more…

Week 10: Buy-back Requirement and Reduced Risk Retention for Qualifying CRE, Commercial or Automobile Loans

In the tenth installment of our weekly series, we examine the buy-back requirement under the proposed credit risk retention rules and reduced risk retention for qualifying commercial real estate, commercial or automobile loans. Read more…

Week 11: General Exemptions from Proposed Risk Retention Rules

In the final installment of our weekly series on credit risk retention under Dodd-Frank, we examine the general exemptions from the credit risk retention requirements. Read more…

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