November 10, 2014

US Bank Regulators Publish FAQs and 2014 SNC Review of Leveraged Lending

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On November 7, 2014, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “agencies”) released the widely anticipated answers to Frequently Asked Questions (the “FAQs”) relating to the March 2013 interagency guidance on leveraged lending (the “2013 Guidance”). The agencies simultaneously released the Shared National Credit (“SNC”) Program 2014 Review, which includes a supplement relating exclusively to leveraged loans (the “SNC Leveraged Loan Supplement” and, together with the FAQs, collectively, the “Additional Guidance”). Copies of the Additional Guidance are included with this note.

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Autoren und Mitwirkende

Bjorn Bjerke

Partner

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+1 212 848 4607

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Maura O’Sullivan

Partner

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Michael Steinberg

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Ronan Wicks

Of Counsel

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+1 212 848 5258

New York