Title IX Overview: Investor Protections and Improvements to the Regulation of Securities

American Bankers Association Contacts

Cris Naser (202) 663-5332 (Credit Rating Agencies/Securitization)
Bob Davis  (202) 663-5588 (Risk Retention)
Joe Pigg (202) 663-5480 (Risk Retention)

Dechert LLP Authors

Stephen H. Bier (212) 698-3889 (Executive Compensation/Corporate Governance)
Elliott R. Curzon (202) 261-3341 (Investor Protection)
William K. Dodds (212) 698-3557 (Enforcement)
Kathleen Massey (212) 698-3686 (Enforcement)
Gordon Sung (212) 649-8786 (Enforcement)
Justin C. Danilewitz (215) 994-2629 (Enforcement)
Ruth S. Epstein (202) 261-3322 (SEC Match Funding & Annuity Exemptions)
Christopher D. Carlson (202) 261-3320 (SEC Match Funding)
Edward L. Pittman (202) 261-3387 (Municipal Securities)
Timothy A. Stafford (212) 698-3504 (Credit Rating Agencies)
Matthew D. Root (212) 698-3881 (Credit Rating Agencies)
Bene Ness (617) 728-7178 (Credit Rating Agencies)
Joshua A. Strathman (949) 442-6016 (Asset Backed Securities Risk Retention)


Summary

Title IX contains a broad set of initiatives intended to improve (i) investor protection in a variety of areas; (ii) securities disclosures, including disclosures regarding executive compensation and asset-backed securities; and (iii) securities enforcement, including improvements to the timeliness of the enforcement process.

Title IX also seeks to address areas that have been identified as contributing to the 2008-2009 financial crisis. Among other things, it imposes risk retention requirements in connection with certain asset-backed securities and by reforming the regulation of credit rating agencies.

The risk retention provisions are likely to have a significant impact on the operations of depository institutions and their affiliates. Federal regulators will have substantial discretion to tailor the implementing regulations to address the nature of the assets involved and the underwriting characteristics of the underlying assets in a particular securitization.

The following links provide expanded analysis within this section: