A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk Identification, Assessment, and Response (“Analytic Framework”); and (2) the updated Guidance for Nonbank Financial Company Determinations (“Nonbank Designations Guidance”). The Analytic Framework was published today in […]
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FSOC Issues Proposed Update to Interpretative Guidance on Nonbank Financial Company Designations
A&B Abstract: On April 21, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) issued for public comment (1) a proposed analytic framework setting forth FSOC’s approach to identifying, evaluating, and addressing potential risks to financial stability (“Proposed Analytic Framework”), and (2) proposed revisions to FSOC’s existing 2019 interpretive guidance that FSOC would use […]
FHFA Proposes New Minimum Financial Requirements for Fannie Mae and Freddie Mac Seller/Servicers
A&B ABstract In keeping with broader scrutiny on non-bank servicers, the Federal Housing Finance Agency (FHFA) is proposing new financial eligibility requirement for non-bank servicers doing business with Fannie Mae or Freddie Mac. The Proposal: On January 31, the FHFA proposed new financial eligibility requirements for approved nonbank Seller/Servicers doing business with Fannie Mae or […]