Final Credit Risk Retention Requirements For Asset-Backed Securities Transactions

I. Introduction

On October 21-22, 2014, the federal regulatory agencies responsible for implementing regulations under The Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") finalized rules for risk retention requirements in asset-backed securities (as further defined below, "ABS") transactions.¹  The final rules (the "Final Rules")² contain clarifications and revisions to the reproposed rules (the "Reproposed Rules")³ highlighted in Part II–Executive Summary of Significant Changes from the Reproposed Rules below, but in most respects the Final Rules are substantially the same as the Reproposed Rules.  Parts III through VII below are a restatement of our prior Clients & Friends Memo⁴ updated to reflect the Final Rules.