Nathan Greene

Nathan Greene

Shearman & Sterling LLP

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Financial Regulatory Developments Focus - August 2015 #4

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

8/26/2015 - Administrative Appointments Banking Sector Broker-Dealer Citigroup Derivatives EU European Commission Financial Institutions Financial Markets Fraud Hedge Funds Investment Adviser Leverage Ratio Payment Systems Prudential Regulation Authority SEC Securities Fraud

Financial Regulatory Developments Focus - August 2015 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

8/19/2015 - Administrative Appointments Banking Sector CFPB CFTC Competition Authorities Derivatives Enforcement Actions European Banking Authority Federal Reserve OCC Prudential Regulation Authority Prudential Standards UK

Financial Regulatory Developments Focus - August 2015 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

8/12/2015 - Banking Sector Capital Requirements Commodity Futures Contracts Derivatives EU Financial Institutions Major Swap Participants Pay Ratio Prudential Standards Regulatory Standards Security-Based Swaps UK

Financial Regulatory Developments Focus - August 2015

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

8/5/2015 - Banking Sector European Banking Authority Federal Reserve Financial Conduct Authority Financial Institutions Financial Markets Financial Services Industry Investment Funds Prudential Regulation Authority Regulatory Agenda

Financial Regulatory Developments Focus - July 2015 #5

In this week’s newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

7/29/2015 - Banking Sector CFTC Derivatives Financial Conduct Authority Financial Institutions Investment Funds Investment Management Prudential Regulation Authority UK

Financial Regulatory Developments Focus - July 2015 #4

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

7/21/2015 - Asset Management Banking Sector Broker-Dealer Capital Requirements EU Financial Institutions G-SIB Investment Firms Regulatory Agencies Regulatory Agenda Ring-Fencing Stress Tests Volcker Rule

Financial Regulatory Developments Focus - July 2015 #3

In this issue: - US Federal Deposit Insurance Corporation Issues Notice of Proposed Rulemaking to Revise How Small Banks are Assessed for Deposit Insurance - UK Prudential Regulation Authority Consults on...more

7/16/2015 - Asset Management Banking Sector Broker-Dealer Corporate Governance Credit Ratings Cybersecurity EU Financial Services Industry Global Market Prudential Regulation Authority Prudential Standards Regulatory Agenda UK

India: Recent Developments Regarding Minimum Alternate Tax

Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place...more

7/13/2015 - Alternative Investment Funds Alternative Minimum Tax Foreign Investment India Investment Funds

SEC Issues Proposed Investment Company Reporting Rules

Global financial regulators continue to push to dampen risk in the system and to improve their readiness to respond to the next crisis. After an initial focus on banks and insurance companies, that regulatory attention has...more

6/1/2015

SEC Issues Proposed Investment Adviser Reporting and Disclosure Rules

In the wake of the financial crisis, the US Securities and Exchange Commission adopted detailed data reporting rules for private funds on both Form ADV (2010) and Form PF (2011). In its continuing push to gather more asset...more

5/29/2015 - Form ADV Investment Adviser Investment Advisers Act of 1940 Rule 204-2 SEC Umbrella Registration

CFTC Staff Issues Revised No-Action Relief from CPO Registration for Certain Delegating CPOs

On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued a no-action letter (“Letter 14-126”)1 providing conditional relief from...more

10/20/2014 - CFTC CPOs Delegation Clauses No-Action Relief Registration

CFTC Staff Issues Exemptive Letter Facilitating Broader Marketing of Certain Commodity Pools

On September 9, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued an exemptive letter (“Letter”) harmonizing certain CFTC restrictions on...more

9/22/2014 - Advertising CFTC CPO General Solicitation JOBS Act Opinion Letter Regulation D Rule 506(c)

Volcker Unbound

The regulation that will implement the Volcker Rule was finally issued on December 10, 2013. Major financial institutions around the world will have to review a host of activities and investments in order to comply with the...more

1/2/2014 - Banks Dodd-Frank Volcker Rule

The Final Volcker Rule Begins to Emerge

We issued a client memorandum on December 9 listing the major topics to look for when the five financial regulatory agencies agreed to finalize the Volcker Rule, which generally prohibits banking organizations from engaging...more

12/11/2013 - Banks Private Investment Funds Volcker Rule

The Volcker Rule: A Comparison

On December 10 2013, the final regulation implementing the Volcker Rule was adopted by the five US federal bank regulatory agencies. This comes over two years after the publication of the proposed regulation. The text below...more

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

Ready for the Volcker Rule? What to Look For

Over two years after publication of a proposed regulation, a final regulation implementing the so-called “Volcker Rule” is expected to be adopted tomorrow by the five US Federal financial regulatory agencies. Two of them —...more

12/9/2013 - CFTC Compliance Federal Reserve Financial Regulatory Reform Volcker Rule

SEC Approves Amendment to FINRA IPO Allocation Rule 5131, Easing Compliance for Fund Investors

Introduction - On November 27, 2013, the Securities and Exchange Commission (“SEC”) approved a change (the “Amendment”) to FINRA’s IPO allocation rule 5131 (the “Rule”).The Amendment allows a fund-of-funds to rely on a...more

12/9/2013 - FINRA Investment Funds Investors IPO SEC

CFTC Adopts Harmonization Rules for CPOs of Registered Investment Companies

The US Commodity Futures Trading Commission (“CFTC”) has adopted widely anticipated rules regarding the application of its commodity pool operator (“CPO”) regulatory regime to CPOs of registered investment companies...more

8/23/2013 - CFTC CPO International Harmonization Investment Funds Registration

As the Deadline Approaches…AIFMD: Marketing by Non-EEA Managers

The AIFMD is due to take effect on July 22, 2013. Yet countries across the EEA — with less than a week until the deadline — are at different stages of transposing the AIFMD into national laws. A number will miss the...more

7/18/2013 - AIFMD Deadlines EEA Managers Marketing New Regulations

SEC Adopts Rule Changes Allowing General Solicitation in Private Placements Under Rule 506 of Regulation D and Rule 144A

On July 10, 2013, the US Securities and Exchange Commission (the “SEC”) adopted rule changes that will permit general solicitation and general advertising in securities offerings under Rule 506 of Regulation D and Rule 144A....more

7/15/2013 - Advertising Dodd-Frank General Solicitation JOBS Act Marketing Private Placements Rule 144A Rule 506 Offerings SEC

SEC Compliance Program Annual Reviews: A Guide for Newly Registered Advisers

The Securities and Exchange Commission estimates that approximately 1,300 hedge and private equity fund managers registered as investment advisers with the agency as a result of the Dodd-Frank Wall Street Reform and Consumer...more

6/13/2013 - Compliance Financial Adviser Investment Adviser SEC

SEC Lawyer Speaks To Broker-Dealer Registration Status Of Private Fund Managers

Late last week, a senior SEC lawyer encouraged the private equity and hedge fund communities to consider whether certain practices of private fund managers could subject these firms to SEC registration as broker-dealers....more

4/11/2013 - Broker-Dealer Fund Managers Private Funds Registration SEC

Life After CPO Registration: Select CFTC and NFA Compliance Obligations that Lie Ahead

Over the last few months, an exceptional number of investment management firms have either registered or prepared to register with the Commodity Futures Trading Commission (“CFTC”) as “commodity pool operators” (“CPOs”). Many...more

3/11/2013 - CFTC CPO Disclosure Requirements NFA Recordkeeping Requirements Registration

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