Sarah Riddell

Sarah Riddell

Morgan Lewis

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NYDFS: “First-In-The-Nation” Cybersecurity Proposal

New “first-in-the-nation” cybersecurity rules in the pipeline for banks, insurers, and financial services companies regulated in New York could prove costly for companies, but will they improve cybersecurity?...more

9/21/2016 - CISO Covered Entities Cybersecurity Cybersecurity Framework Financial Institutions Notice Requirements NYDFS Third-Party Service Provider

NFA Proposal Would Require CFTC-Registered Asset Managers to Report on Financial Condition

The National Futures Association’s (NFA’s) latest proposal would require registered commodity pool operators and commodity trading advisors to provide new information about their financial condition in quarterly reports to...more

9/16/2016 - Asset Management Capital Requirements CFTC Commodity Pool CPO CTA Financial Sector NFA SEC

CFTC Proposes Permanent Registration Relief to Certain Non-US Asset Managers

The amendments to the CFTC’s registration rules will codify no-action relief that permits non-US asset managers to rely on an exemption from the requirement to register with the CFTC by virtue of trading uncleared swaps in...more

8/4/2016 - Asset Management Brokers CFTC Commodity Pool CPOs CTA No-Action Relief Non-US Entities Proposed Rules Registration Requirement Uncleared Swaps

Deadline Approaches for Annual CPO/CTA Exemption Filings

Firms must affirm their exemption or exclusion from CPO or CTA registration on the National Futures Association’s Exemption Filing System by February 29....more

1/12/2016 - CFTC Commodities CPO CTA Exemptions Filing Deadlines NFA

The Conference of State Bank Supervisors Adopts Model Regulatory Framework for Virtual-Currency Businesses

Addressing regulatory concerns pertaining to consumer protection, market stability, and law enforcement, the Framework expands on the CSBS draft framework released in December 2014. The Conference of State Bank...more

10/15/2015 - Bank Secrecy Act BitLicense CSBS Cybersecurity Disaster Preparedness Disclosure Requirements EFTA Licenses NMLS Notice Requirements NYDFS Regulatory Standards Risk Management Startups Third-Party Virtual Currency

National Futures Association Proposes Cybersecurity Guidance for NFA Member Firms

NFA links NFA’s supervisory requirements with its proposed requirements mandating that NFA Members have information systems security programs. The National Futures Association (NFA) has proposed cybersecurity...more

9/8/2015 - Board of Directors C-Suite Executives CFTC Cyber Threats Cybersecurity Data Protection Data Security Financial Institutions FINRA Incident Response Plans Information Security National Futures Association NIST Proposed Regulation SEC Security Risk Assessments

CFTC Staff Exempts Certain Commodity Trading Advisors from Form CTA-PR Reporting

The reporting relief applies to commodity trading advisors that do not “direct” trading of any client commodity interest trading accounts. On July 23, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued...more

7/28/2015 - CFTC Commodity Broker Commodity Interest Commodity Pool CTA Exemptions Investment Adviser National Futures Association Reporting Requirements Swap Dealers

CFTC Proposes Amendments to Recordkeeping Rules

Proposed changes would provide permanent relief from compliance with certain recordkeeping requirements and narrow the types of records that must be identifiable by transaction. The December 2012 amendments to...more

11/10/2014 - CFTC CTA DCMs FCMs Proposed Amendments Recordkeeping Requirements SEFs

SEC Proposes Enhanced Regulatory Framework for Certain Registered Clearing Agencies

The proposal is consistent with international recommendations and Basel III criteria. On March 12, the Securities and Exchange Commission (SEC) proposed new rules and rule amendments (the Proposal) that would enhance...more

3/21/2014 - Basel III CFTC Clearing Agencies Dodd-Frank FSOC Proposed Regulation Risk Assessment Risk Management SEC

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