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December 10, 2025
Cadwalader partner Peter Malyshev was recently quoted in Green Street News’ Asset-Backed Alert article, “CFTC OKs Risk-Transfer Exemption.”
Peter commented on the Federal Reserve’s approach to credit risk transfer transactions, noting that other banks may seek additional regulatory relief beyond the scope of the Fed’s recent no-action letter, which currently applies only to regulated financial institutions that are members of the Structured Finance Association.
He also explained that while banks can reduce regulatory capital requirements by directly issuing credit-linked notes with Fed approval, the process can be slowed by approval timelines and limits on transaction size — factors that complicate execution for large institutions.
Read the full article here (subscription required).
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