Bradley Phipps

Bradley Phipps

DLA Piper

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Net worth threshold for "qualified clients" under Investment Advisers Act will increase effective 8/15/2016

Effective as of August 15, 2016, the net worth threshold for qualified clients under Investment Advisers Act Rule 205-3 will increase from $2 million to $2.1 million. ...more

7/6/2016 - Advisory Contracts High Net-Worth Investment Advisers Act of 1940 Performance Fee Rule Qualified Client Registered Investment Advisors SEC

Global Financial Markets Insight - Issue 9, Q1 2016

The beginning of 2016 has proved uncomfortable for markets. The fall in oil prices, the downturn of the Chinese markets and the continued uncertainty over Europe continue to drive a negative and uncertain outlook. With...more

3/3/2016 - Bonds BRRD Central Counterparties EU European Central Bank Financial Sector FinTech Margin Requirements Oil Prices Peer-to-Peer Portugal Project Finance Prospectus Securitization Vehicles UK

Annual privacy notice requirement eliminated for certain financial institutions

In December, President Barack Obama signed into law the Fixing America’s Surface Transportation Act. Buried on page 476 of this 490-page bill is an amendment to the consumer privacy provisions of the Gramm-Leach-Bliley Act...more

1/18/2016 - CFTC Fixing America’s Surface Transportation Act (FAST Act) Gramm-Leach-Blilely Act Notice of Privacy Practices SEC

Life on the margin: US margin rules finalized at last

More than five years after the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the US Commodity Futures Trading Commission has adopted a final rule regarding margin for uncleared swaps (the CFTC...more

1/12/2016 - CFTC Exemptions Major Swap Participants Margin Requirements Uncleared Swaps

SEC proposes substantial new reporting requirements for investment advisers on Form ADV: key points

The Securities and Exchange Commission has issued proposed rules (the Proposal) under the Investment Advisers Act of 1940, as amended, that would, among other things, expand the information collected on Form ADV, provide for...more

6/4/2015 - Affiliates Disclosure Requirements Form ADV Investment Adviser Investment Advisers Act of 1940 NPRM Recordkeeping Requirements Reporting Requirements SEC Separate Accounts Umbrella Registration

SEC proposes requiring FINRA membership for exchange-member-only broker-dealers

The Securities and Exchange Commission has published a proposal to amend SEC Rule 15b9-1 under the Securities Exchange Act of 1934, as amended, which exempts certain broker-dealers from membership in a registered national...more

4/2/2015 - Broker-Dealer Exemptions FINRA Hedging High Frequency Trading Rule 15B9-1 SEC Securities Exchange Act

Dodd-Frank affects private companies too: practice points to note

The Dodd-Frank Act – signed by President Barack Obama more than three years ago, and since then advanced with a host of rules and regulations – has been widely viewed as a law that addresses systemic risk in the financial...more

12/4/2013 - Dodd-Frank Executive Compensation Fiduciary Duty NYSE SEC Shareholders Whistleblowers

European Commission and CFTC announce a path forward on cross-border regulation of OTC derivatives

On July 11, 2013, the Commodity Futures Trading Commission and the European Commission announced a high-level joint understanding (referred to in the announcement as the “Path Forward”) regarding the approach to the...more

7/12/2013 - CFTC Cross-Border EMIR EU European Commission OTC Swap Dealers

CFTC approves final cross-border guidance of the swap provisions of the Dodd-Frank Act

Following yesterday’s announcement by the Commodity Futures Trading Commission and the European Commission of a joint understanding regarding a coordinated approach to the regulation of cross-border derivatives (for a further...more

7/12/2013 - Aggregation Rules CEA CFTC Cross-Border Transactions Dodd-Frank EMIR EU Major Swap Participants Risk Mitigation Swap Dealers Swaps

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