[20140505]IF00022_沃尔克规则的结构、使用和实施.pdf

May 5, 2014 Collateralized Loan Obligations (CLOs), Structure, Use, and Implementation of the Volcker Rule Overview A collateralized loan obligation (CLO) is one way to fund debt through a trust that issues securities. Recent rulemaking to implement Section 619 (the Volcker Rule) of the Dodd-Frank Act focused attention on bank participation in CLOs. This article provides a general overview of the CLO structure; with a particular focus on CLOs that have been used by banks to fund commercial debt, and discusses regulatory policies of CLOs in relation to the Volcker Rule. Some policymakers are concerned that the December 2013 final regulation for the Volcker Rule may create unintended hardship for banks that own interests in CLOs originated prior to the issuance of the rule. There is proposed legislation (H.R. 4167) designed to address these concerns. General Definition and Structure of a CLO CLOs are a subset of the more general category of collateralized debt obligations (CDOs). In a CDO, a trust is formed to hold debt. The debt might be loans or bonds, and thus there are CLOs for loans and CBOs for bonds. The difference between a CLO and a CBO is that bonds are generally more easi