Dodd-Frank Title VII – update

Further to the information we released in October 2014 in order to raise awareness around the potential implications of Dodd-Frank Title VII on trade finance risk participations, we are pleased to provide you with an update on this matter.
The high-level data on secondary market risk participation volumes that was submitted to ITFA by a number of market participants was very useful and appreciated, as it enabled the Association to provide this on an aggregated and confidential basis to BAFT.

25 institutions responded, stating that they had executed a total of 2,145 MRPAs, and distributed USD 137.3 billion (of which USD 52.5 billion were unfunded participations).

Sullivan and Cromwell (S&C) have therefore integrated this data, together with other feedback they have gathered during discussions with representatives from our industry, and finalised their memo. This has subsequently been submitted it to the Federal Banking Agencies (namely the Federal Reserve, OCC and FDIC). A copy of the memo can be viewed by clicking here.

We look forward to sending out another update in due course based on the reactions received by S&C and BAFT.

Kindest regards