Credit Risk Retention Final Rule: Steering CMBS through the Regulatory Wake

October 27, 2014

After more than three and a half years since the publication by regulators of the first proposals for credit risk retention, we now have a final rule that has brought with it a myriad of reactions: dissent, relief and perplexity, among others. In the world of commercial mortgage-backed securities (“CMBS”), we have come a long way – for example, since the original proposal resulted in comments from over 10,500 parties and since we wondered how we could ever live with the premium capture cash reserve account mechanism (which was excluded in re-proposed rules last year) – but questions remain and we have work to do before the final rule goes live in about two years.

Read "Credit Risk Retention Final Rule: Steering CMBS through the Regulatory Wake."