The Loan Syndications and Trading Association ('LSTA') provides model agency provisions that reflect standard market practice in the United Sates primary loan markets, while the Loan Market Association ('LMA') provides model provisions reflecting market practices in the European markets. In the U.S., the administrative and collateral agent is typically the same institution as (or an affiliate of) the lead arranger. By contrast, in Europe, the administrative agent is a separate institution from the lead bank and arranger, and may also be a different institution from the collateral agent. This distinction leads to numerous differences in how the LSTA and the LMA provisions deal with agents, a few of which are discussed in this article on lexology.com.
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