Ignacio A. Sandoval

Ignacio A. Sandoval

Morgan Lewis

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CFTC/SEC Jurisdictional Battle Heats Up Over Dividend Indices

The CFTC recently approved a futures contract on a dividend index as a non-security based index futures contract over the SEC’s objection that the dividend index contract could be a security future; the CFTC’s actions may...more

8/20/2015 - CEA CFTC Commodities Commodity Futures Contracts Commodity Futures Modernization Act of 2000 (CFMA) Dividends Index Contracts SEC Securities Swap Market

Select Broker-Dealer Enforcement Cases and Developments: 2014 Year in Review

This Outline highlights key U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) and Financial Industry Regulatory Authority (“FINRA”) enforcement developments and cases regarding broker dealers.* The...more

2/20/2015 - Broker-Dealer Enforcement Enforcement Actions Municipal Securities Issuers SEC Whistleblowers

SEC Extends AML Relief for Broker-Dealer CIP Reliance on Advisers

The SEC’s action suggests that formal antimoney laundering program requirements for investment advisers may be on the horizon. On January 9, the staff of the U.S. Securities and Exchange Commission (SEC) issued the...more

1/19/2015 - Anti-Money Laundering Bank Secrecy Act FinCEN Investment Adviser No-Action Relief NOPR Reporting Requirements SEC SIFMA U.S. Treasury

New Best Execution Requirement for Municipal Securities Transactions

Although the MSRB’s new best execution rule is generally consistent with FINRA’s, differences exist and questions remain regarding FINRA’s examination and enforcement of the requirements....more

1/15/2015 - Enforcement FINRA MSRB Municipal Securities Issuers Municipal Securities Market Municipalities

FINRA and MSRB Seek Disclosure of Fixed-Income Price Differentials

The respective proposals would require disclosure of price differentials in certain same-day fixed-income transactions that involve retail customers and go beyond existing price differential disclosure requirements in equity...more

12/10/2014 - Disclosure Requirements FINRA MSRB

SEC Adopts Regulation SCI

On November 19, 2014, the U.S. Securities and Exchange Commission (SEC) unanimously adopted Regulation Systems Compliance and Integrity (Regulation SCI) under the Securities Exchange Act of 1934 (Exchange Act). Regulation SCI...more

12/9/2014 - Covered Entities Financial Markets Market Participants Regulation SCI SEC Securities Exchange Act

FinCEN Proposes to Expand Financial Institution Customer Due Diligence Requirements

The proposal would require financial institutions to identify beneficial owners of legal entities and codify existing customer due diligence guidance....more

8/6/2014 - Anti-Money Laundering Bank Secrecy Act Banks Compliance Due Diligence FCMs FinCEN SEC

Challenges in Requiring High-Frequency Traders to Register as Dealers

SEC Chair Mary Jo White outlined a broad market structure proposal that would require high-frequency traders to register with the SEC as dealers and that could signal the end of the dealer-trader distinction....more

6/11/2014 - Broker-Dealer Compliance Enforcement High Frequency Trading Registration SEC

SEC Issues FAQs on Financial Responsibility Rules

The guidance addresses expense arrangements, buy-in procedures, free credit balances, sweep programs, and bulk transfers, among other things. On March 6, the staff of the Securities and Exchange Commission (SEC) issued...more

3/12/2014 - Broker-Dealer Customer Protection Rule FINRA Net Capital Rule SEC

SEC Issues Relief from Certain Financial Responsibility Rule Requirements

In two separate letters, the SEC staff addresses operational concerns raised by broker-dealers in connection with sweep program authorizations and the use of certain nonaffiliated U.S. branches of foreign banks....more

3/3/2014 - Banks Broker-Dealer Foreign Banks SEC Securities Exchange Act

Select Broker-Dealer, Investment Adviser, and Investment Company Enforcement Cases and Developments: 2013 Year in Review

Table of Contents: Executive Summary; U.S. Securities and Exchange Commission; and Financial Industry Regulatory Authority. Executive Summary - This Outline highlights key U.S. Securities and Exchange...more

2/19/2014 - Broker-Dealer Enforcement Actions FINRA Investment Adviser SEC

SEC Provides No-Action Relief for M&A Brokers

SEC staff action may head off congressional action to exempt M&A Brokers from registration. On February 3, the staff of the Securities and Exchange Commission (SEC) issued a no-action letter that permits an M&A broker...more

2/6/2014 - Broker-Dealer Brokers Compliance No-Action Relief SEC Securities Exchange Act

Temporary Exemption from Certain SEC Financial Responsibility Rules Amendments

The limited exemption will provide broker-dealers with more time to make necessary operational or systems changes. On October 17, the Securities and Exchange Commission (SEC) issued an order providing a temporary...more

10/21/2013 - Broker-Dealer Exemptions Net Capital Rule SEC Securities Exchange Act

SEC Amends Financial Responsibility Rules for Broker-Dealers

Amendments impact many aspects of broker-dealers' back-office operations and will require changes to a number of existing practices. On July 30, the Securities and Exchange Commission (SEC) adopted amendments to the...more

8/28/2013 - Banks Broker-Dealer Capital Requirements New Regulations Risk Management SEC Securities Exchange Act Surety & Fidelity

SEC Provides Relief for Familiarization Activities of Foreign Options Markets

The no-action relief provided by the staff of the Division of Trading and Markets is generally consistent with the relief previously provided to foreign options markets. On July 1, the staff of the Securities and...more

7/18/2013 - Equitable Relief Foreign Investment Foreign Markets SEC Secondary Markets

SEC Permits Portfolio Margining of Credit Default Swaps

Order grants exemptive relief from Exchange Act requirements; parallel CFTC relief expected soon. On December 14, the Securities and Exchange Commission (SEC) issued an order granting exemptive relief (Exemptive Order)...more

12/31/2012 - Broker-Dealer CEA CFTC Derivatives Clearing Organizations Exemptive Orders SEC Swaps

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