Milbank partner Deborah Festa and associate Andrew Keller wrote an article titled “US Risk Retention Rules: What Constitutes an Open-Market CLO?,” which was published in the July 18, 2018 edition of The Review of Securities & Commodities Regulation. The article examines application of the recent LSTA decision on risk retention in the context of cross-trades, principal transactions and other call-and-roll type transactions.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
