On October 30, 2019, SEC Chairman Jay Clayton announced that the SEC will review its RMBS asset-level disclosure requirements with “an eye toward facilitating SEC-registered offerings.”   The announcement notes the absence of SEC-registered RMBS securitizations in recent years and seeks input from investors, issuers and other market participants with respect to several questions posed in

On July 25th, the CFPB announced plans to allow the temporary Qualified Mortgage (QM) status given to loans eligible for purchase by Fannie Mae or Freddie Mac (the GSEs) to expire. However, the agency stated it could allow a short extension past the January 10, 2021 expiration date, and is in any case soliciting public comments on the general QM definition, including its income and debt documentation requirements.
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In this inaugural edition of our Structured Finance Bulletin, we discuss some trending issues that began impacting the structured finance and asset-backed and mortgage-backed securities spaces in late 2018, which will play a more prominent role in the execution and marketing of securitization transactions in 2019.
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A repurchase facility (“Repurchase Facility”) is a financing arrangement pursuant to which a bank or other credit institution (a “Buyer”) provides liquidity to an entity that originates or acquires real estate related assets (a “Seller”) by purchasing such assets with a simultaneous agreement that the Seller will repurchase the assets on a future date.  A Repurchase Facility may be used to aggregate mortgage loans or other qualifying assets that a Seller has originated prior to a takeout in connection with a securitization, or a Repurchase Facility could be used to provide financing for a static pool through the maturity date of the mortgage loans.

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