William Stern

William Stern

Goodwin Procter LLP

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SEC Releases Risk Alert Related to Outsourcing of Chief Compliance Officer Duties by Investment Advisers and Investment Companies

On Nov. 9, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert reporting observations from its examination of investment advisers and investment companies that outsource their Chief...more

11/12/2015 - Anti-Money Laundering Chief Compliance Officers FinCEN OCIE Outsourcing Risk Alert SEC

CFTC Takes First Action Against Virtual Currency Options Trading Platform

On Thursday, Sept. 17, 2015, the U.S. Commodity Futures Trading Commission (CFTC) issued an Order against San Francisco-based Coinflip and its chief executive officer, Francisco Riordan, to resolve allegations that Coinflip...more

9/23/2015 - Bitcoin Cease and Desist Orders CFTC Commodities Exchange Act Digital Currency Enforcement Actions Swaps Unregistered Securities

Federal Regulators Issue Volcker Rule FAQ Addressing Investment Fund Seeding Periods

The Volcker rule generally prohibits banking entities from engaging in proprietary trading and from sponsoring and/or investing in certain types of “covered” investment funds. The implementing regulation that the Agencies...more

7/20/2015 - Business Development Companies CFTC Covered Banking Entity FDIC Federal Reserve Investment Adviser Investment Companies New Guidance OCC Proprietary Trading SEC Seed Financing Volcker Rule

Federal Agencies Issue Final Policy Statement Regarding Standards for Assessing Diversity Policies and Practices

On June 9, 2015, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Bureau of Consumer...more

7/7/2015 - Assessment Board of Directors Diversity Diversity and Inclusion Standards (D&I) Dodd-Frank Equal Opportunities Federal Register Hiring & Firing Joint Policy Statements OMWI Public Disclosure Securities Exchange Act Suppliers

Financial Services Weekly News Roundup - June 2015 #3

Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

6/18/2015 - Anti-Money Laundering Bank Secrecy Act Brokers CFTC Civil Monetary Penalty Community Banks Enforcement Enforcement Actions FDIC Financial Institutions FinCEN Investment Adviser No-Action Letters No-Action Relief Reporting Requirements Swap Dealers Swaps

Financial Services Weekly News Roundup - June 2015 #2

Regulatory Developments: SEC Chair Highlights Recent Accomplishments - In a June 4, 2015 speech, SEC Chair Mary Jo White highlighted recent activities of the SEC and identified work to be done in the near future....more

6/11/2015 - Avon Banks Broker-Dealer Comptroller Dodd-Frank EDGAR FDIC Federal Reserve Financial Institutions FINRA Investment Adviser JOBS Act Market Manipulation National Bank Act SEC

Financial Services Weekly News Roundup - June 2015

Regulatory Developments: Superintendent Lawsky Announces Final BitLicense Regulations - New York State Department of Financial Services (NYDFS) Superintendent Benjamin Lawsky, at the BITS Emerging Payments Forum,...more

6/4/2015 - Banking Sector Banks BEA Bitcoin BitLicense Broker-Dealer Dodd-Frank DOL Fiduciary Duty FINRA Foreign Investment Form BE-10 OCC SEC Virtual Currency

Federal Reserve Extends Volcker Rule Conformance Period for Covered Funds Activities for One Year

The Board of Governors of the Federal Reserve System announced yesterday afternoon that it has extended the conformance period under the Volcker rule for one additional year—until July 21, 2016—to allow banking entities to...more


Federal Banking Agencies Sharpen Scrutiny of Leveraged Lending

Following a slide in lending standards and an increase in leveraged loan volume, new guidance from the federal banking agencies suggests a tightening of credit standards for leveraged loans from regulated banking...more

11/19/2014 - Banks Investment Funds Leveraged Loans Priority Guidance Plan Prudential Regulation Authority

OFAC Issues New Guidance Regarding Status of Entities Owned by Specially Designated Nationals and Blocked Persons

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance regarding the status of entities that are 50% or more owned by persons or entities whose property and interests in property are...more

8/20/2014 - Blocked Person Executive Orders OFAC Sanctions SDN List SSI List U.S. Treasury Ukraine

FINCEN Issues Proposed Revisions to its Regulations That Would Enhance Financial Institutions’ Customer Due Diligence Requirements

The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has proposed revisions (the “Proposal”) to its rules implementing the Bank Secrecy Act (the “BSA”) that would spell out specific anti-money...more

8/13/2014 - Anti-Money Laundering Bank Secrecy Act Banks Compliance Due Diligence FinCEN

Bitcoin Does Not Need a Ban, It Needs Enlightened Regulation

If an outright ban of Bitcoin is not the correct approach, what is? More to the point, what does Bitcoin (and virtual currency in general) need to for legitimacy?...more

2/27/2014 - Bitcoin Legal Perspectives Virtual Currency

Could Bitcoin Make Retail Cybersecurity Obsolete?

Interesting question, but life is never easy, and digital currency brings its own set of challenges...more

2/3/2014 - Bitcoin Cybersecurity Law Matters Legal Perspectives Virtual Currency

Proprietary Trading Aspects of the Volcker Rule – Frequently Asked Questions

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the “SEC”) issued a final rule, and the Commodity Futures...more

1/2/2014 - Banking Reform Bill Compliance Covered Banking Entity Dodd-Frank Final Rules Financial Instruments Foreign Investment Hedging Market Making Proprietary Trading Reporting Requirements Risk Mitigation Underwriting Volcker Rule

Covered Funds Aspects of the Volcker Rule – Frequently Asked Questions

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the "SEC") issued a final rule, and the Commodity Futures...more

12/20/2013 - Asset Management Asset-Backed Securities Bank Holding Company Act Banks Bonds CFTC Dodd-Frank FDIC Federal Reserve Fiduciary Duty Financial Market Utilities FSOC Joint Venture Life Insurance Nonbank Firms OCC Pensions Private Funds Proprietary Trading REIT Retirement Plan SEC SIFIs Subsidiaries Tender Offers Venture Capital Volcker Rule

What Banks and Trust Companies Need to Know About the SEC’s New Municipal Advisor Rules

The SEC’s final Municipal Advisor Rules, effective January 13, 2014, apply to many of the advisory services and products provided by banks and trust companies to municipal entities, such as state and local governments, and to...more

11/26/2013 - Banks Municipal Advisers SEC Trusts

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