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Federal Reserve Board Provides New Details on Volcker Rule’s Illiquid Funds Requirements

On December 12, 2016, the Federal Reserve Board announced additional details regarding how banking entities may seek an extension to conform their investments in a narrow class of funds that qualify as “illiquid funds” to the...more

12/22/2016  /  Banking Sector , Banks , Dodd-Frank , FRB , Volcker Rule

SEC Office of Compliance Inspections and Examinations Issues Risk Alert on Whistleblower Rule Compliance

On October 24, Staff in the Office of Compliance Inspections and Examinations (the “Staff”) issued a National Exam Program Risk Alert announcing that it is examining registered investment advisers and registered...more

Federal Reserve Announces Extension of Conformance Period Under Section 13 of the Bank Holding Company Act

On July 7, 2016, the Federal Reserve announced that it will extend until July 21, 2017 the conformance period for banking entities to divest ownership in certain legacy investment funds and terminate relationships with funds...more

SEC Issues Order Increasing the Net Worth Test Under Rule 205-3 Under the Investment Advisers Act of 1940 to $2.1 Million

Section 205(a)(1) of the Investment Advisers Act of 1940 (the “Advisers Act”) generally prohibits an investment adviser from entering into, extending, renewing, or performing any investment advisory contract that provides for...more

Derivatives in Review - April 2016

Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more

Federal District Court Rules against Designation of MetLife as a “SIFI” under Dodd-Frank Act

On March 30, the D.C. federal District Court ruled against the designation by the Financial Stability Oversight Counsel (“FSOC”) of MetLife as a “systemically important financial institution” under the Dodd-Frank Act. The...more

Derivatives in Review - December 2015

Prudential Regulators Approve Final Uncleared Margin Rules - In October, the prudential regulators approved a final version of the September 2014 re-proposed rule generally imposing initial and variation margin...more

FinCEN Proposes New Rule Requiring Anti-Money Laundering Programs for Registered Investment Advisers

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that would define investment advisers registered (or required to be registered) with the Securities and...more

Federal Reserve Acts to Extend Conformance Period Under Volcker Rule for Legacy Covered Funds Until July 2017

On December 18, the Federal Reserve Board announced that it has acted under Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, commonly known as the Volcker Rule, to give banking entities until July...more

The New CFTC Regulatory Regime For Private Fund Managers; First Quarter 2013 Update

The enactment of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and its implementation by the Commodity Futures Trading Commission (“CFTC”) has ushered in a new era of...more

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