What is a TALF CMBS-Eligible Rating Agency?
The New York Fed is currently engaged in a review process of the rating methodologies of all rating agencies that have expressed an interest in rating TALF-financed CMBS. A list of TALF CMBS-eligible rating agencies and the required number of TALF CMBS-eligible rating agencies from which TALF-eligible CMBS must obtain a rating will be released upon completion of this review and prior to the initial CMBS subscription date.
When is the initial subscription date for CMBS?
The initial CMBS subscription date will be in late June. The specific date will be announced shortly. The subscription and settlement cycle for CMBS will occur in the latter part of each month, whereas the cycle for non-CMBS ABS TALF asset classes and premium finance ABS will remain at the beginning of the month.
What kind of assurances will be required to confirm that the CMBS is TALF eligible?
The framework for an issuer/sponsor certification and auditor certification is being developed and will be announced shortly.
Will issuers be able to reserve TALF funding capacity for deals that will take several months to assemble and bring to market?
The New York Fed is considering a process to permit interested issuers, through a process to be determined, to reserve prospective funding of TALF loans collateralized by new issue CMBS. The New York Fed expects that each potential issuer to which such a reservation is awarded will pay a monthly reservation fee as a fraction of the amount reserved for every month that the reservation is outstanding until the CMBS is issued. Funding of a TALF loan in connection with such a reservation will be subject to satisfaction of all of the requirements of the TALF program relating to eligible collateral and eligible borrowers. No reservation will extend beyond the last CMBS subscription. If implemented, details of this process will be announced shortly.