Russell Sacks

Russell Sacks

Shearman & Sterling LLP

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ESMA Advice on Third-Country Equivalence Under EMIR, II

On 3 September, ESMA published its technical advice to the European Commission on the equivalence of the US and Japanese derivatives frameworks to the EU rules. On 2 October, ESMA supplemented its technical advice with...more

10/22/2013 - Derivatives EMIR Equivalency Determinations ESMA EU European Commission Japan

Preferring Foreign Depositors – The Final Rule

The Federal Deposit Insurance Corporation has issued a final rule adopting with virtually no change its proposed approach to depositor preference for deposits payable at foreign offices of US banks. While the rule will...more

9/16/2013 - Banks FDIC Foreign Banks National Depositor Preference Regimes

ESMA Advice on Third-Country Equivalence Under EMIR

Clarity to market participants on the equivalence of derivatives rules to European requirements has been much anticipated. On 3 September, ESMA published its technical advice to the European Commission on the equivalence of...more

9/6/2013 - Derivatives EMIR Equivalency Determinations ESMA EU Financial Regulatory Reform

Another Dodd-Frank Tax on Size: The Fed Charges for Big-Bank Supervision

An obscure section of the Dodd-Frank Act has been implemented by the Federal Reserve, to be effective later this year. Traditionally the Federal Reserve has not charged examination or similar fees for institutions under its...more

8/23/2013 - Banks Dodd-Frank Federal Reserve

SEC Adopts Changes to Broker-Dealer Net Capital and Financial Responsibility Rules

The US Securities and Exchange Commission recently adopted important changes to the financial responsibility rules for securities broker-dealers, including changes to the regulatory capital and regulatory reporting rules. The...more

8/20/2013 - Broker-Dealer Compliance Customer Protection Rule GAAP Lenders Net Capital Rule New Regulations Recordkeeping Requirements Reporting Requirements Risk Mitigation SEC

Alert: ESMA Consults on Extraterritoriality

The extraterritorial effect of new financial regulation is a controversial issue, fundamental to the business of banks, brokers, funds and their clients. A consultation paper containing proposed rules on certain...more

8/5/2013 - Cross-Border EMIR ESMA EU European Commission Extraterritoriality Rules

FINRA Proposes to Publicly Disseminate Transaction Information Regarding Rule 144A Corporate Debt Securities

FINRA has proposed a trade-reporting rule change that would result in the public dissemination of secondary market transactions in corporate debt securities sold under Securities Act Rule 144A. If adopted, this change could...more

7/18/2013 - Compliance FINRA Rule 144A SEC Secondary Markets Securities Act of 1933

Private Placement Update: FINRA Proposes Form of Electronic Filing for Private Placements Under Rule 5123

On June 20, 2013, the U.S. Financial Industry Regulatory Authority, Inc. (“FINRA”) filed a proposed rule change with the Securities and Exchange Commission (“SEC”) concerning the obligations of members under FINRA Rule 5123...more

6/25/2013 - E-Filing FINRA Private Placements Proposed Amendments SEC

Fed Rewrites Section 716 of Dodd-Frank

The Federal Reserve on Wednesday, June 5, issued an interpretation of the so-called “swaps push-out” section of the Dodd-Frank Act that corrects a drafting error that virtually everyone agrees needed to be fixed. The Federal...more

6/10/2013 - Dodd-Frank FDIC Federal Reserve Foreign Banks OCC Swap Dealers Swaps

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

Preferring Foreign Depositors

The Federal Deposit Insurance Corporation has issued a proposed regulation intended to address an emerging issue in international banking: how to grant non-US branch deposits equal treatment with US deposits in the event of...more

4/10/2013 - FDIC International Banks

SEC Releases Responses To Frequently Asked Questions Regarding Rule 15a-6 And Foreign Broker-Dealers

On March 21, 2013, the staff of the Division of Trading and Markets (the “Staff”) of the US Securities and Exchange Commission (the “SEC”) released responses reflecting the Staff’s views on frequently asked questions (the...more

3/25/2013 - Broker-Dealer Rule 15a-6 SEC

What’s Going On – Over A Month Of Section 219 Disclosures Under The Iran Threat Reduction And Syria Human Rights Act Of 2012

Section 219 (codified as Section 13(r) of the Securities Exchange Act) has been in effect for six weeks. During this time, more than 100 SEC-registered reporting issuers have made required disclosures regarding their Iran or...more

3/20/2013 - Iran Threat Reduction and Syria Human Rights Act Reporting Requirements

Thinking Ahead: Breaking Down FINRA’s Revised Proposed Fixed-Income Research Rule

In the fourth quarter of 2012, FINRA published Regulatory Notice 12-42 (the “Revised Proposal”), amending its proposal for substantive regulation of fixed-income research by FINRA-member firms. The Revised Proposal represents...more

3/18/2013 - FINRA Qualified Institutional Buyers

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