News & Analysis as of September 20, 2024

European Union › No-Action Letters

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The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of WWII. The EU maintains a common currency as well as several intranational institutions, including the European Parliament and the European Commission. less -

European Banking Authority Responds to European Commission's Delegated Act Postponing Application of Market Risk Framework

A&O Shearman on 9/6/2024

The European Banking Authority has published a no-action letter in response to the European Commission's postponement of the application of the revised market risk framework, also known as the Fundamental Review of the...more

Extension of Brexit No-Action Letters

Orrick, Herrington & Sutcliffe LLP on 12/23/2020

In November 2020, the CFTC published two no-action letters extending previously granted no-action relief related to Brexit. The relief was intended to provide “greater certainty to the global marketplace” in connection with...more

SEC Extends Temporary Relief for MiFID II-Compliant Research Payments

Vedder Price on 12/10/2019

On October 26, 2017, the SEC staff issued a no-action letter providing relief to broker-dealers that provide research that constitutes “investment advice” under the Investment Advisers Act of 1940 to investment managers...more

US Securities and Exchange Commission Extends No-Action Relief for MiFID II Inducements and Research

A&O Shearman on 11/21/2019

The U.K. Financial Conduct Authority has welcomed the U.S. Securities and Exchange Commission’s extension of no-action relief addressing a potential conflict between U.S. regulation and the inducements and research provisions...more

US Commodity Futures Trading Commission Issues No-Action Letters to Ensure Continued Relief and Substituted Compliance for U.K....

A&O Shearman on 4/25/2019

The Commodity Futures Trading Commission has issued two no-action letters to ensure that existing regulatory relief and substituted compliance measures for EU firms will continue to apply to U.K. firms following the U.K.’s...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - April 2019

Skadden, Arps, Slate, Meagher & Flom LLP on 4/16/2019

In this issue, we examine the release of the much-anticipated Strategic Hub for Innovation and Financial Technology (FinHub) guidance for analyzing how U.S. federal securities laws apply to initial coin offerings, the...more

CFTC Clears Decks for "No Deal" Brexit

Jones Day on 4/15/2019

The Commodity Futures Trading Commission ("CFTC") extends no-action and exemptive relief from the European Union to the United Kingdom. On April 5, 2019, the CFTC's Divisions of Clearing and Risk, Market Oversight and Swap...more

Corporate & Financial Weekly Digest, Featuring Articles on the SEC's New Framework for Cryptocurrencies and Fresh Guidance From...

Katten Muchin Rosenman LLP on 4/8/2019

BROKER-DEALER - Nasdaq Proposes Rule Change to SEC to Assume Operational Responsibility for Certain Investigation and Enforcement Functions Currently Performed by FINRA - On April 3, the Securities and Exchange...more

Investment Services Regulatory Update - January 2019

Vedder Price on 1/30/2019

New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes New Fund-of-Funds Rule – On December 19, 2018, the SEC proposed new Rule 12d1-4 under the Investment Company Act of 1940, which, if...more

Orrick's Financial Industry Week In Review

Orrick, Herrington & Sutcliffe LLP on 5/18/2018

Division of Investment Management of the SEC Issues No-Action Letter to SSB - On May 8, 2018, the Chief Counsel's Office of the Division of Investment Management ("IM") of the Securities and Exchange Commission (the...more

Corporate and Financial Weekly Digest, Featuring Topics on Broker/Dealer, CFTC and UK/EU/Brexit Developments

Katten Muchin Rosenman LLP on 3/2/2018

BROKER-DEALER - FINRA Requests Comment on Proposed New Rule Governing Outside Business Activities On February 26, the Financial Industry Regulatory Authority released Regulatory Notice 18-08, which solicits comments on...more

Analysis of the SEC’s MiFID II No-Action Relief

Proskauer Rose LLP on 1/25/2018

On October 26, 2017, the Securities and Exchange Commission ("SEC" or the "Commission") staff issued three no-action letters to help broker-dealers, investment advisers and investment companies comply with the European...more

Broker-Dealer Beat - December 2017

Proskauer Rose LLP on 12/7/2017

Unbundling research and execution costs for money managers subject to MiFID II means that US broker-dealers can expect to receive hard dollars or other separately identified payments for research, at least from EU managers....more

Investment Services Regulatory Update - November 2017

Vedder Price on 11/21/2017

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more

SEC Staff Issues No-Action Relief to Facilitate Implementation of MiFID II Research Provisions

Goodwin on 11/13/2017

On October 26, 2017, the staff (the Staff) of the U.S. Securities and Exchange Commission (SEC) issued three related no-action letters providing market participants with greater clarity as to how certain aspects of their...more

Asset Management Regulatory Roundup - November 2017 - Issue 9

Dechert LLP on 11/1/2017

A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details on SEC’s no action letters and Commission’s FAQs on “hard dollar” research payments under...more

Orrick's Financial Industry Week In Review

Orrick, Herrington & Sutcliffe LLP on 8/4/2017

FHFA Updates Progress on Fannie Mae and Freddie Mac Credit Risk Transfer Programs - On July 26, 2017, the Federal Housing Finance Agency released an update on the credit risk transfer programs of Freddie Mac and Fannie Mae...more

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on 12/23/2016

FHFA Issues Final Rule on Fannie Mae and Freddie Mac Duty to Serve Underserved Markets - On December 13, 2016, the Federal Housing Finance Agency (FHFA) issued a final rule implementing the Duty to Serve provisions...more

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on 9/16/2016

Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more

Corporate and Financial Weekly Digest - Volume XI, Issue 15

Katten Muchin Rosenman LLP on 4/18/2016

SEC/CORPORATE - SEC Publishes Concept Release Regarding Business and Financial Disclosure - On April 13, the Securities and Exchange Commission published a concept release, recommended by the SEC’s Division of...more

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on 3/2/2016

Bureau of Consumer Financial Protection Issues Policy on No-Action Letters - On February 18, the Consumer Financial Protection Bureau issued a new policy statement on No-Action Letters. Under the Policy, Bureau...more

Corporate and Financial Weekly Digest - Volume XI, Issue 8

Katten Muchin Rosenman LLP on 2/29/2016

BROKER-DEALER - FINRA Requests Information Regarding Firm Culture and Values - The Financial Industry Regulatory Authority is requesting firms to submit information regarding their organizational culture and how...more

Corporate and Financial Weekly Digest - Volume XI, Issue 7

Katten Muchin Rosenman LLP on 2/22/2016

SEC/CORPORATE - SEC Advisory Committee on Small and Emerging Companies to Discuss Capital Formation Landscape for Small and Emerging Companies - The Securities and Exchange Commission announced that its Advisory...more

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on 7/28/2015

The Restructuring Mid-Summer Review: Europe and the Emerging Markets - For those focused on the debt restructuring market, the Greek sovereign crisis (covered extensively in our recent updates1) has drowned out news of...more

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on 4/8/2015

RMBS Claims Against Ratings Agencies Dismissed as Time-Barred - On March 27, Judge John Robert Blakely of the U.S. District Court for the Northern District of Illinois granted Standard & Poor's Financial Services, LLC's...more

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European Union › No-Action Letters

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