On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the characterization of underlying partnership debt as recourse vs. nonrecourse under Section 752 of the Internal Revenue Code.

On Friday, the Office of the Comptroller of the Currency closed Home National Bank, headquartered in Blackwell, Oklahoma, and the FDIC was appointed receiver.

On Friday, the New York State Banking Department closed USA Bank, headquartered in Port Chester, New York, and the FDIC was appointed receiver.