Nathan Greene

Nathan Greene

Shearman & Sterling LLP

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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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