This website stores cookies on your computer. These cookies are used to improve your website experience and provide more personalized services to you, both on this website and through other media. To find out more about the cookies we use, see our Cookie Policy.
Accept Decline
mobile logo
  • Search
  • People
  • Capabilities
  • Global Reach
  • Insights
      NewsEventsViewpoints
  • About
      About UsDiversity, Equity and InclusionCommunity Engagement + Pro BonoCareersAlumni
  • ביוגרפיות
      ביוגרפיותישראל
logo
    People
    Capabilities
    Global Reach
    Insights +
    About +
    Eng +
Search

Trade & Export Finance

Marquee Image
Overview
People
Matters
Viewpoints
News
Events
Trade Finance Videos

March 30, 2026

–Deal News

Sullivan Advises BAFT and ITFA on Updated CRR Legal Opinions Covering the Suite of Master Participation Agreements (MPAs)

  • Share this page:

(London and New York) – Sullivan has advised BAFT (the Bankers Association for Finance & Trade) and ITFA (the International Trade and Forfaiting Association) in relation to updated Capital Requirements Regulation (CRR) legal opinions covering the suite of English and New York law Master Participation Agreements (MPAs).

These generic opinions can be utilised by BAFT and ITFA members’ in-house counsel to create ‘enforceability opinions’. They can also be used as part of the analysis of the effectiveness of MPAs as credit risk mitigants under CRR. However, a number of factual matters must be satisfied under CRR to obtain full effectiveness and these will depend on each user’s own circumstances. A further guidance note has also been published to accompany the opinions.

Updates are now available through BAFT and ITFA’s websites for members, as follows:

  • Guidance note relating to the opinions
  • EU CRR opinion on English law MPA 2018
  • UK CRR opinion on English law MPA 2018
  • EU CRR opinion on NY law MPA 2019
  • UK CRR opinion on NY law MPA 2019
  • NY law enforceability opinion on NY law MPA 2019
  • EU CRR opinion on Surety MPA
  • UK CRR opinion on Surety MPA

It is worth noting that separate opinions have now been created for EU vs UK CRR, reflecting post-Brexit changes. Also, the updated opinion for the 2008 English law MPA is not yet available, as changes to the regulations are making it more challenging to issue a clean opinion. This will be released as soon as possible, together with guidance on the updated scope. As the underlying 2008 document has long been superseded, no longer further opinions will be issued after this final one has been published.

Geoffrey Wynne, head of Sullivan’s Trade & Export Finance Group, commented: “Sullivan is pleased to have advised both BAFT and ITFA in relation to the publication of these important updated opinions. They form a key part of the analysis of the effectiveness of MPAs as credit risk mitigants under CRR. As such they remain invaluable to the trade finance market as a whole. It is worth re-stating that a number of factual matters must be satisfied under CRR to obtain full effectiveness and these will depend on each user’s own circumstances.”

The Sullivan team advising BAFT and ITFA included partners Geoffrey Wynne and Marian Boyle in London and partner Natalie Lederman in New York.

In 2023 Sullivan advised BAFT and ITFA on the CRR opinions on the MPAs for both the 2008 and 2019 English law versions, as well as the New York 2019 version as updated for the LIBOR transition.

In March 2025, Sullivan assisted BAFT and its working group on the 2025 BAFT Master Trade Loan Agreement (2025 BAFT MTLA), designed as an industry-standard document, used for lending between financial institutions to finance or refinance specified trade transactions.

In April 2025, Sullivan worked with an ITFA working group to develop a Short Term SWIFT Financial Institution (FI) Trade Loan Template - a new template intended to help streamline trade finance transactions between banks.

About Sullivan
Sullivan & Worcester (Sullivan) is a global law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best in class client service.

For further information, please visit the firm’s website and LinkedIn.

Related People

  • Marian J. Boyle
  • Natalie S. Lederman
  • Geoffrey Wynne

Capabilities

  • Trade & Export Finance
  • United Kingdom
Overview People Matters Viewpoints News Events Trade Finance Videos

Featured

Events
Slush 2026

Sullivan & Worcester will once again participate in Slush 2026, taking place November 18-19 in Helsinki, Finland. One of the world's leading startup events, Slush brings together entrepreneurs and investors from around the globe, offering a unique opportunity to connect with the Nordic technology community and explore new business opportunities. Representing the firm's Emerging Companies & Venture Capital, Intellectual Property and Mergers & Acquisitions practices, Sullivan's team will include Scott Kaufman, Mike Palmisciano, Michael

News
Financing the Future: From Defence to Critical Raw Materials

Geoffrey Wynne⁠ has been quoted in  an article for the International Trade and Forfaiting Association (ITFA), written by Clarissa Dann, titled “Financing the Future: From Defence to Critical Raw Materials⁠”, following a panel discussion at ITFA’s 52nd Annual Conference in Split, Croatia where he was a panellist. The article examines the growing demand for finance across critical raw materials, defence and energy transition supply chains and the challenges of attracting capital

Viewpoints
John Graham Submits Comments to Treasury and IRS on Proposed Regulations for Racial Nondiscrimination in Private Schools

John Graham submitted comments to the U.S. Department of the Treasury and Internal Revenue Service in response to proposed regulations addressing racial nondiscrimination requirements for private schools under Section 501(c)(3). In his comments, Graham supports the longstanding rule that private schools engaging in racial discrimination do not qualify as charitable organizations under Section 501(c)(3), while urging Treasury and the IRS to clarify that remedial, inclusive race-conscious scholarship and outreach programs designed

News
Sullivan Advises The RMR Group on $272.1 Million Cedars-Sinai Medical Office Portfolio Refinancing

Sullivan represented a joint venture managed by The RMR Group in a $272.1 million interest-only mortgage financing secured by two 11-story medical office buildings totaling approximately 330,000 square feet and two parking garages on the Cedars-Sinai Medical Center campus in Los Angeles. Cedars-Sinai and its affiliates occupy approximately 60% of the portfolio’s rentable space. RMR client Diversified Healthcare Trust (Nasdaq: DHC) holds a 20% equity interest in the joint venture, which

News
Sullivan & Worcester Earns National and Regional Rankings in 2027 Best Law Firms®
Viewpoints
Personnel Records Law Changes the Terrain for New York Employers and Workers

A new law requires New York employers to give their employees access to their own personnel records upon request. This law (New York Labor Law Section 210-b) goes into effect November 8, 2026. What is a personnel record? The law defines a personnel record as a record that identifies an employee “to the extent that the record is used or has been used, or may affect or be used relative to that

Events
Looking ahead or back to basics? ECA reform priorities to remain competitive

Partner Mark Norris⁠ will participate in GTR Africa 2026 London, hosted by Global Trade Review (GTR) on November 12, the theme for which is “Charting Africa’s trade and export trajectory.” Mark will join the panel discussing “Looking ahead or back to basics? ECA reform priorities to remain competitive”, which will be moderated by Chris Mitman at Acre Impact Capital and include Ram Shalita at Bluebird Finance & Projects and Anders Vium

Viewpoints
Q&A with Harvey E. Bines, Attorney at Sullivan & Worcester: Insights on the Wolters Kluwer Treatise Investment Management Law and Regulation

Partner Harvey E. Bines was recently featured in a Q&A with citybiz, discussing his legal career and his work as co-author of Investment Management Law and Regulation, a comprehensive legal treatise published by Wolters Kluwer. First published in 1978, the treatise examines the legal and regulatory framework governing investment management and has evolved alongside significant developments in the industry. In the interview, Harvey reflects on the treatise's origins and how it

Viewpoints
Funds and Advisers Quarterly Regulatory Update

Sullivan & Worcester introduces the debut issue of its Funds and Advisers Quarterly Regulatory Update, covering the period from August 1 through October 31, 2026. This new quarterly newsletter provides a concise overview of significant legal, regulatory and enforcement developments affecting registered funds, private funds, investment advisers and independent directors. Each edition highlights key developments and emerging issues, offering practical insights to help industry professionals stay informed and anticipate changes

Events
Export Finance: Unlocking Government-Backed Funding for International Expansion

Sullivan & Worcester will host two events in London and Edinburgh on 11 and 12 November, 2026, as part of International Trade Week 2026, exploring how export credit agency (ECA) financing can help venture-backed technology companies fund international growth without diluting equity. Partners James Shaw, Ben Williams, Daniela Barrdear and Mark Norris, from the firm's Emerging Companies & Venture Capital and Trade & Export Finance practices, will discuss how UK Export

Events
Slush 2026

Sullivan & Worcester will once again participate in Slush 2026, taking place November 18-19 in Helsinki, Finland. One of the world's leading startup events, Slush brings together entrepreneurs and investors from around the globe, offering a unique opportunity to connect with the Nordic technology community and explore new business opportunities. Representing the firm's Emerging Companies & Venture Capital, Intellectual Property and Mergers & Acquisitions practices, Sullivan's team will include Scott Kaufman, Mike Palmisciano, Michael

News
Financing the Future: From Defence to Critical Raw Materials

Geoffrey Wynne⁠ has been quoted in  an article for the International Trade and Forfaiting Association (ITFA), written by Clarissa Dann, titled “Financing the Future: From Defence to Critical Raw Materials⁠”, following a panel discussion at ITFA’s 52nd Annual Conference in Split, Croatia where he was a panellist. The article examines the growing demand for finance across critical raw materials, defence and energy transition supply chains and the challenges of attracting capital

Viewpoints
John Graham Submits Comments to Treasury and IRS on Proposed Regulations for Racial Nondiscrimination in Private Schools

John Graham submitted comments to the U.S. Department of the Treasury and Internal Revenue Service in response to proposed regulations addressing racial nondiscrimination requirements for private schools under Section 501(c)(3). In his comments, Graham supports the longstanding rule that private schools engaging in racial discrimination do not qualify as charitable organizations under Section 501(c)(3), while urging Treasury and the IRS to clarify that remedial, inclusive race-conscious scholarship and outreach programs designed

News
Sullivan Advises The RMR Group on $272.1 Million Cedars-Sinai Medical Office Portfolio Refinancing

Sullivan represented a joint venture managed by The RMR Group in a $272.1 million interest-only mortgage financing secured by two 11-story medical office buildings totaling approximately 330,000 square feet and two parking garages on the Cedars-Sinai Medical Center campus in Los Angeles. Cedars-Sinai and its affiliates occupy approximately 60% of the portfolio’s rentable space. RMR client Diversified Healthcare Trust (Nasdaq: DHC) holds a 20% equity interest in the joint venture, which

News
Sullivan & Worcester Earns National and Regional Rankings in 2027 Best Law Firms®
Viewpoints
Personnel Records Law Changes the Terrain for New York Employers and Workers

A new law requires New York employers to give their employees access to their own personnel records upon request. This law (New York Labor Law Section 210-b) goes into effect November 8, 2026. What is a personnel record? The law defines a personnel record as a record that identifies an employee “to the extent that the record is used or has been used, or may affect or be used relative to that

Contact Us
Boston, MA
New York, NY
London, UK
Washington, DC
Tel Aviv, Israel
1251 Avenue of the Americas
19th Floor
New York, NY 10020
212 660 3000
More
brand-overlay
  • Contact Us
  • Terms of Use
  • Legal Notices
  • Cookie Policy
  • Privacy Policy
  • Attorney Advertising
  • Website Credits

Stay Connected

  • Alerts and Events
  • Sullivan Alumni

Careers

Join Our Team
Hebrew

© 2026 Sullivan & Worcester. All rights reserved.

This website does not track your personal or demographic information, only anonymous usage statistics. To ensure that you are not tracked, we have blocked all embedded content from third party sources like YouTube and SlideShare. Click "Accept Cookies" to enable third-party content. To learn more about our cookie policy, click here.
Accept CookiesNo Thanks