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ARTICLE · 20 SEPTEMBER 2019

Recent Credit Card ABS Disclosure Trends

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In July, the Federal Deposit Insurance Corporation (the "FDIC") proposed a change (discussed here) to certain provisions of its securitization safe harbor rule (the "Rule"),

United StatesFinance and Banking
Julie A. Gillespie
Julie A. Gillespie
Jan Stewart
Jan Stewart
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Jeffrey Taft
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John-David Treumann
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In July, the Federal Deposit Insurance Corporation (the "FDIC") proposed a change (discussed here) to certain provisions of its securitization safe harbor rule (the "Rule"), which relates to the treatment of financial assets transferred in connection with a securitization or participation transaction. The proposed change would eliminate the requirement under the Rule that disclosure documents for bank-sponsored securitizations not otherwise subject to Regulation AB's disclosure requirements (i.e. non-public transactions) comply with Regulation AB. This could significantly ease the compliance burden associated with non-public bank-sponsored ABS issuances, potentially resulting in a greater volume of such transactions.

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