The U.S. Securities and Exchange Commission recently adopted a new Rule 192 (the “Final Rule”) under the Securities Act of 1933, as amended (the “Securities Act”) to prohibit conflicts of interest in certain securitizations. While the SEC’s original re-proposal of the rule in January 2023 (the “Proposed Rule”) raised a number of concerns for banks and other entities engaging in credit risk transfer transactions for risk-management and capital relief purposes, the Final Rule includes important changes that limit the impact on such transactions. The compliance date for the Final Rule is June 9, 2025. This client briefing will provide an overview of aspects of the Final Rule that are particularly important for banks and other entities participating in CRT transactions as they prepare for the compliance date.

Download PDF
211kb