On August 5, 2015, the SEC adopted a final rule to implement Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, often referred to as the pay-ratio provision.
The pay-ratio provision mandates...more
On August 5, 2015, the Securities and Exchange Commission (“SEC”) adopted long-awaited final rules on CEO pay ratio disclosure (the “Rules”), which require that almost every SEC registrant disclose the ratio of the annual...more
On August 5, 2015, the Securities and Exchange Commission (SEC) voted 3-2 to approve its controversial pay ratio rules. The rules were adopted pursuant to the mandate of Section 953(b)(1) of the Dodd-Frank Wall Street Reform...more
Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more
Increasingly, we receive questions from prospective investors in covered bonds on whether an investment is prohibited or limited under the Volcker Rule, which was adopted by the various agencies under section 619 of the...more
U.S. regulation of money managers, including non-U.S. managers, and the funds they manage is a complex regime that has changed significantly since the implementation of the Dodd-Frank Reform and Consumer Protection Act of...more
The House and Senate have passed legislation which provides that swap end-users do not have to provide initial and variation margin for uncleared swaps as previously required by the Dodd-Frank Act.
The provision is...more
More consumer credit and leasing transactions will be subject to the Truth in Lending Act (TILA) and Consumer Leasing Act (CLA) in 2015.
Effective January 1, 2015, the dollar threshold for exemption of most consumer...more
In June 2014, the Washington State Department of Financial Institutions, Securities Division amended the rules applicable to investment advisers in the state of Washington in Chapter 460-24A of the Washington Administrative...more
Resisting the CFPB’s enforcement petition filed in the United States District Court for the Central District of California, as they resisted the petition in proceedings before the CFPB, a group of tribally-affiliated lenders...more
The SEC adopted amendments to the expiration dates of certain interim final rules adopted in July 2011. The interim final rules provide exemptions under the Securities Act of 1933, the Securities Exchange Act of 1934, and...more
On December 18, 2013, the SEC published its proposal to modify Regulation A. The SEC is proposing to expand Regulation A into two tiers: Tier 1, for offerings of up to $5 million; and Tier 2, for offerings of up to $50...more
The five US financial agencies (“Agencies”) have approved jointly prepared final regulations (“Final Rules”) to implement the prohibitions on engaging in proprietary trading and investment in or sponsorship of a private...more
On Monday, November 25, 2013, the Consumer Financial Protection Bureau (the “Bureau”) issued final rules amending its Regulation Z (Truth In Lending) and Regulation M (Consumer Leasing) in accordance with the requirements of...more
After several years and 18,000 comments, yesterday regulators braved a “snow covered” Washington and voted to approve a final rule to prohibit banks from engaging in proprietary trading, known as the Volcker rule. As industry...more
Five federal financial regulatory agencies have released final rules implementing Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Section 619 created Section 13 in the Bank Holding Company Act...more
On December 10, 2013, five U.S. financial regulators (the Agencies) adopted a final rule implementing the Volcker Rule. The text of the final rule and its accompanying preamble are available here. The Volcker Rule was created...more
The so-called Volcker Rule, as required to be implemented by the Dodd-Frank Act, generally prohibits any banking entity from engaging in proprietary trading. The final rule has been adopted by the Office of the Comptroller...more
Staff responds to industry concerns and confusion surrounding SEF operations and onboarding.
One of the key aspects of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) is...more
CFTC Approves Final Cooperative Swap Clearing Exemption Rule and Issues Time-Limited No-Action Relied -
On Tuesday, August 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) issued a final rule to exempt...more
As required by the Dodd-Frank Act, the SEC on July 10, 2013, adopted final Rule 506(d) to "disqualify felons and other bad actors" from Regulation D private offerings. New Rule 506(d) identifies persons and triggering events...more
On June 21, 2013, the Department of Labor (DOL) published proposed amendments to certain class exemptions required by Section 939 A of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which directs federal...more
This past January, the Securities and Exchange Commission (the SEC) approved new corporate governance listing rules proposed by each of the New York Stock Exchange (the NYSE) and the Nasdaq Stock Market (the NASDAQ) pursuant...more
On May 23, the Federal Reserve Board issued a report showing that the exemption designed to protect small debit card issuers from interchange fee standards applied to large issuers is working as intended. ...more
Companies must comply with certain final NYSE and NASDAQ listing rules by July 1.
By July 1, affected companies must comply with recent amendments to the listing rules of the New York Stock Exchange (NYSE) and the...more
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