Robert Rhatigan

Robert Rhatigan

Dechert LLP

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Credit Risk Retention Final Rule: Enforcement and Compliance Considerations

Predicting enforcement of the final rule regarding U.S. risk retention is an uncertain task. This OnPoint is designed to provide guidance on possibilities related to consequences of non-compliance, enforcement approaches by...more

12/16/2014 - Asset-Backed Securities CMBS Collateralized Loan Obligations Dodd-Frank Enforcement Guidance Final Rules Private Right of Action Prudential Regulation Authority Risk Retention

SEC Brings Settled Administrative Proceedings Against NYSE Relating to Informational Advantages, Electronic Trading and Other...

The Securities and Exchange Commission (SEC or Commission) on May 1, 2014 announced a settlement (Settlement) with the New York Stock Exchange LLC and certain of its affiliates (collectively, the NYSE), addressing a variety...more

6/6/2014 - Affiliates Civil Monetary Penalty Co-Location Compliance Electronic Trading Enforcement Enforcement Actions High Frequency Trading Information Sharing Neither Admit Nor Deny Settlements NYSE SEC Settlement

CFTC Extends Certain SEF Reporting, Confirmation, and Documentation Compliance Dates

commoThe Division of Market Oversight (“Division”) of the U.S. Commodity Futures Trading Commission (“CFTC”) on September 27 and 30, 2013 issued several no-action letters to temporarily registered swap execution facilities...more

10/7/2013 - Asset Class CFTC Commodities Exchange Act Compliance Confirmation Proceedings Documentation Reporting Requirements SEFs Swaps

Disparate Impact Discrimination Remains in the Spotlight: Insurance Industry Trade Groups Challenge HUD’s Disparate Impact Rule

Two insurance industry trade groups, the American Insurance Association and the National Association of Mutual Insurance Companies, recently filed suit against the U.S. Department of Housing and Urban Development (HUD)...more

8/13/2013 - Discrimination Disparate Impact Fair Housing Act HUD McCarran-Ferguson Act SCOTUS

SEC Adopts Retail Foreign Exchange Rule in Order to Prevent Dodd-Frank Amendment from Disrupting the Retail Forex Markets

The U.S. Securities and Exchange Commission (“SEC”) on July 11, 2013 adopted Rule 15b12-1 (“Final Rule”) under the Securities Exchange Act of 1934 as amended (“Exchange Act”) in order to allow market participants to continue...more

8/5/2013 - CEA Disruptive Trading Practices Dodd-Frank Eligible Contract Participant Final Rules Foreign Exchanges Retail Market SEC

2012 Bank Enforcement Actions Still High, But Significantly Lower Than 2010-11

Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more

4/4/2013 - Anti-Money Laundering CFPB Enforcement Actions Fair Lending FCRA FDIC FinCEN Mortgage Reform OCC OFAC Unfair or Deceptive Trade Practices

IOSCO and FSB Recommend Additional Money Market Fund Reform, Putting International Pressure on the SEC to Take Action

Introduction - The International Organization of Securities Commissions (IOSCO), an international organization of securities regulators, recently published its “Policy Recommendations for Money Market Funds” (Final...more

1/4/2013 - FSB International Finance IOSCO Money Market Funds SEC

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