David Portilla

David Portilla

Shearman & Sterling LLP

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Basel III Framework: US/EU Comparison

The US and EU rules implementing Basel III follow many aspects of Basel III closely, but there are major differences in approach in several key areas. Financial institutions have been engaged in a “race to the top” to show...more

9/17/2013 - Basel III EU Financial Regulatory Reform

Preferring Foreign Depositors – The Final Rule

The Federal Deposit Insurance Corporation has issued a final rule adopting with virtually no change its proposed approach to depositor preference for deposits payable at foreign offices of US banks. While the rule will...more

9/16/2013 - Banks FDIC Foreign Banks National Depositor Preference Regimes

Another Dodd-Frank Tax on Size: The Fed Charges for Big-Bank Supervision

An obscure section of the Dodd-Frank Act has been implemented by the Federal Reserve, to be effective later this year. Traditionally the Federal Reserve has not charged examination or similar fees for institutions under its...more

8/23/2013 - Banks Dodd-Frank Federal Reserve

SEC Adopts Changes to Broker-Dealer Net Capital and Financial Responsibility Rules

The US Securities and Exchange Commission recently adopted important changes to the financial responsibility rules for securities broker-dealers, including changes to the regulatory capital and regulatory reporting rules. The...more

8/20/2013 - Broker-Dealer Compliance Customer Protection Rule GAAP Lenders Net Capital Rule New Regulations Recordkeeping Requirements Reporting Requirements Risk Mitigation SEC

Actions Required Under Derivatives Reforms

The first wave of financial regulatory change affecting banks, brokers and their users is in the field of derivatives. Various deadlines for new reporting, clearing and conduct of business requirements are imminent. The...more

7/31/2013 - Banks Brokers Collateral Derivatives EMIR ESMA Hedge Funds OTC

FINRA Proposes to Publicly Disseminate Transaction Information Regarding Rule 144A Corporate Debt Securities

FINRA has proposed a trade-reporting rule change that would result in the public dissemination of secondary market transactions in corporate debt securities sold under Securities Act Rule 144A. If adopted, this change could...more

7/18/2013 - Compliance FINRA Rule 144A SEC Secondary Markets Securities Act of 1933

Fed Rewrites Section 716 of Dodd-Frank

The Federal Reserve on Wednesday, June 5, issued an interpretation of the so-called “swaps push-out” section of the Dodd-Frank Act that corrects a drafting error that virtually everyone agrees needed to be fixed. The Federal...more

6/10/2013 - Dodd-Frank FDIC Federal Reserve Foreign Banks OCC Swap Dealers Swaps

Preferring Foreign Depositors

The Federal Deposit Insurance Corporation has issued a proposed regulation intended to address an emerging issue in international banking: how to grant non-US branch deposits equal treatment with US deposits in the event of...more

4/10/2013 - FDIC International Banks

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