News & Analysis as of

The Volcker Rule: Overview and Compliance Requirements

Background on the Final Rule - On December 10, 2013, the Board of Governors of the Federal Reserve, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange...more

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

Update On ISDA Protocols

We previously noted certain matters that needed to be completed by May 1, 2013 for those entities engaged in derivatives transactions to allow swap dealers to comply with the CFTC’s External Business Conduct Rule. ...more

SEC Approves FINRA Rule Change That Requires Reporting OTC Equity Transactions Within 10 Seconds

The Securities and Exchange Commission has approved a proposed rule change by the Financial Industry Regulatory Authority requiring that transactions and transaction cancellations in over-the-counter (OTC) equity securities...more

CFTC Approves Clearing Exemption for Inter-Affiliate Swaps

On April 1, the Commodity Futures Trading Commission approved a final rule that permits certain affiliates to elect not to clear a swap. To qualify for the clearing exemption, the counterparties’ financial statements must be...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Applicable Manufacturers

“Applicable Manufacturers” - Common Ownership Considered to be Ownership by the Same Individuals or Entities of 5 Percent or More in Two Entities - In the Final Rule, CMS defines “applicable manufacturer” as an...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Report Submission and Review

Report Submission and Review Pre-Submission Review is Not Required Applicable manufacturers may voluntarily provide covered recipients the opportunity to review the data prior to submission to CMS, but doing so is not...more

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