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CLO Legal League Tables Q3 2025 — Risk Retention Déjà Vu Amid Summer Spree

October 28, 2025

Cadwalader partners Nick Shiren and David Gingold were recently quoted in 9fin’s Q3 2025 CLO Legal League Tables report, “CLO Legal League Tables Q3 25 — Risk Retention Déjà Vu Amid Summer Spree.”

The article highlights a busy summer for CLO lawyers, with steady deal flow and new regulatory developments around European risk retention rules.

Nick Shiren discussed evolving deal documentation trends, noting that the market is introducing new flexibility through aggregation features and periods that allow collateral managers more latitude in meeting reinvestment criteria. “It effectively gives the collateral manager a little bit more flexibility in determining whether or not the reinvestment criteria has been satisfied,” he said.

David Gingold commented on the growing inclusion of PIKable loan provisions in CLO documentation. “Some of the language was already in there, but I've seen managers try to change what the threshold is to be considered for that,” he explained.

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