Illegal Activity
none
Blackmail
none
Date
February 2018
Document Type
memorandum
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
This document is a memorandum discussing the U.S. Credit Risk Retention Regulations and how RREEF intends to comply with them. It outlines the requirements for sponsors of securitization transactions to retain a portion of the credit risk and the potential consequences of failing to comply.
Metadata
- Subject
- US Credit Risk Retention
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0088810, SDNY_GM_00234994
- Date
- February 2018
Relationships 3
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Portfolio Advisor | Compliance | U.S. Risk Retention Regulations | The Portfolio Advisor is considered a 'sponsor' for purposes of the U.S. Risk Retention Regulations and must comply with them. |
| RREEF | Affiliate | Retention Holder | RREEF intends to satisfy the U.S. Risk Retention Regulations through its majority-owned affiliate, the Retention Holder. |
| The Loan Syndications and Trading Association | Legal | Securities and Exchange Commission and Board of Governors of the Federal Reserve System | The Loan Syndications and Trading Association won a case against the Securities and Exchange Commission and Board of Governors of the Federal Reserve System regarding credit risk retention rules. |
Notable Quotes 2
The U.S. Risk Retention Regulations require the 'sponsor' (the 'Sponsor') of a 'securitization transaction' to retain (either directly or through its 'majority-owned affiliates') not less than 5% of the 'credit risk' of 'securitized assets' (as such terms are defined in the U.S. Risk Retention Regulations).
Prospective investors should note the following in reviewing the contents of this section entitled 'US Credit Risk Retention': (i) although the Portfolio Advisor believes in good faith that the U.S. Retention Interest will (together with other actions that the Portfolio Advisor intends to take to satisfy the U.S. Risk Retention Regulations) satisfy the U.S. Risk Retention Regulations (as in effect as of the date of this Private Placement Memorandum) in all material respects, there can be no assurances that the U.S. Retention Interest (together with other actions that the Portfolio Advisor intends to take to satisfy the U.S. Risk Retention Regulations) will satisfy the U.S. Risk Retention Regulations
Financial Information
Amounts:5%
Assets:
- Preferred Shares
- Refinancing Securities
- Initial Facility
Transactions:
- Purchasing an 'eligible vertical interest' on each Preferred Shares Issuance Date in an amount of not less than 5% of the Preferred Shares issued on such date
- Purchasing an 'eligible vertical interest' on the Refinancing Closing Date in an amount of not less than 5% of the principal amount of each class of Refinancing Securities issued by the Issuer on such date
- Acquiring 5% of the Initial Facility on the Initial Facility Closing Date
Legal Compliance
- Potential failure to satisfy the U.S. Risk Retention Regulations could have materially negative effects on the ability of the Portfolio Advisor to perform its obligations under the Portfolio Advisory Agreement.
Raw Analysis JSON
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Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsCompliance issues
Organizations 6
Alpha Group Capital LLCU.S. House Committee on Oversight and AccountabilitySecurities and Exchange CommissionBoard of Governors of the Federal Reserve SystemThe Loan Syndications and Trading AssociationRREEF
Locations 2
U.S.District of Columbia Circuit
Text Analysis
- Tone
- Informative, Legalistic
- Purpose
- To inform prospective investors about the U.S. Credit Risk Retention Regulations and how RREEF intends to comply with them.
- Significance
- This document outlines the steps RREEF is taking to comply with U.S. Risk Retention Regulations, which are designed to ensure that sponsors of securitization transactions retain a portion of the credit risk.
File Info
- File Name
- EFTA01386895.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:38.783518
- DOJ Source
- View on DOJ