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Morgan Lewis Urges NYDFS to Modify Its Re-Proposed Cybersecurity Rules

Morgan Lewis submits second comment letter on the proposed rules. The New York State Department of Financial Services (DFS) is expected soon to issue “first-in-the-nation” cybersecurity regulations that will apply to...more

NYDFS Modifies, Delays Implementation of Cybersecurity Rules

The modified rules, which still remain among the most prohibitive, could be adopted in final form as early as this month. Since September 2016, the New York State Department of Financial Services (DFS) has been...more

Morgan Lewis Urges NYDFS to Modify Proposed Cybersecurity Rules

The New York Department of Financial Services has issued proposed “first-in-the-nation” cybersecurity rules that could place a heavy compliance burden on affected financial companies; Morgan Lewis submitted a comment letter...more

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

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

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

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

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

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

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

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

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