Heather Cruz

Heather Cruz

Skadden, Arps, Slate, Meagher & Flom LLP

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Latest Publications


Department of Labor Proposes New Fiduciary Regulation and Prohibited Transaction Exemption Relief for Investment Advice...

On April 20, 2015, more than three years after withdrawing a similar proposal that was staunchly opposed by the financial services industry, the U.S. Department of Labor (DOL) published in the Federal Register a proposed...more

4/29/2015 - Benefit Plan Sponsors Best Interest Contract Exemptions Broker-Dealer DOL Employee Benefits ERISA Exemptions Fiduciary Duty Financial Institutions Internal Revenue Code (IRC) Investment Adviser IRA Pension Funds Prohibited Transactions

"CFTC Staff Issues More No-Action Letters to Commodity Pool Operators"

Over the last month, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) issued four letters providing exemptive, no-action and interpretative relief to commodity...more

10/24/2014 - CFTC CPOs Delegation of Discretion DSIO Filing Requirements JOBS Act No-Action Relief Recordkeeping Requirements Third-Party

"Parallel Fund Structures Under the Volcker Rule"

Skadden was one of 15 law firms that participated in the development of a recently released consensus interpretation letter regarding the ability of non-U.S. banking entities to invest in certain parallel funds organized by...more

5/15/2014 - Banks Commodity Pool CPO Investment Company Act of 1940 Investment Funds Nonbank Firms Volcker Rule

"Entering a New Regulatory Era Under the Final Volcker Rule"

In December 2013, five U.S. financial regulatory agencies adopted final regulations to implement the Volcker Rule. As expressed in the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Volcker Rule generally...more

1/30/2014 - Banks Collateralized Debt Obligations Dodd-Frank FDIC Proprietary Trading Risk Management Trust Preferred Securities Volcker Rule

The Volcker Rule: A First Look at Key Changes

On December 10, 2013, five U.S. financial regulators (the Agencies) adopted a final rule implementing the Volcker Rule. The text of the final rule and its accompanying preamble are available here. The Volcker Rule was created...more

12/12/2013 - Asset-Backed Securities Banks CEOs Dodd-Frank Exemptions Hedge Funds Market Making Private Equity Reporting Requirements Sovereign Debt Volcker Rule

"US Financial Regulators Issue Final Volcker Rule"

Yesterday, U.S. financial regulators issued the final Volcker Rule. The Volcker Rule implements provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that prohibit banking organizations from engaging in...more

12/11/2013 - Dodd-Frank Financial Regulatory Reform Volcker Rule

"CFTC Staff Provides Funds-of-Funds With Temporary No-Action Relief From Commodity Pool Operator Registration"

On November 29, 2012, the Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) issued temporary no-action relief from commodity pool operator (CPO) registration to...more

12/11/2012 - CFTC Commodity Pool No-Action Relief Swap Dealers

"Gatz Highlights Standards for Affiliated-Party Transactions"

In Gatz Properties, LLC v. Auriga Capital Corp., the Delaware Supreme Court required a manager and controlling member of a Delaware limited liability company to satisfy the entire fairness standard of conduct and judicial...more


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