Last week, Fitch Ratings announced the launch of new ESG ratings system, which is intended to use a "clear methodolog[y]," of a "full assessment of ESG performance" that "allow[s] for detailed comparability." This...more
U.S. Financial Industry Developments - SEC Disapproves the Listing and Trading of Nine Bitcoin Related Exchange Traded Products - On August 22, 2018, the SEC released three Orders, acting through authority delegated to...more
U.S. Financial Industry Developments - CFTC and SEC Announce Approval of New MOU - On June 28, 2018, the Commodity Futures Trading Commission ("CFTC") and the Securities and Exchange Commission ("SEC") announced that...more
U.S. Financial Industry Developments - Credit Agreements Will Require Important Updates If a Proposed New Delaware Law Is Passed - The Delaware legislature is currently contemplating an amendment to the Delaware Limited...more
SEC Proposes to Enhance Protections and Preserve Choice for Retail Investors in Their Relationships with Investment Professionals - On April 18, the Securities and Exchange Commission voted to propose a package of...more
Home Mortgage Disclosure Act: FFIEC's Revised 'A Guide to HMDA Reporting: Getting It Right!' On March 14, 2018, the Office of the Comptroller of the Currency published an updated resource providing guidance for complying...more
SEC Statement on Potentially Unlawful Online Platforms for Trading Digital Assets - On March 7, 2018, the Divisions of Enforcement and Trading and Markets of the Securities and Exchange Commission released a "Statement on...more
Looking Out for Main Street: SEC Focuses on Retail, Cybersecurity and Cryptocurrency - The Commissioners and senior officials of the Securities and Exchange Commission ("SEC" or "Commission") addressed the public on...more
Second Circuit Raises Bar for US Jurisdiction Over Foreign Banks - Orrick litigators Robert Reznick, Stephen Foresta and Julie Gorchkova co-authored an article for Law360 that examines a closely-watched case relating to...more
SEC Division of Investment Management Letter on Cryptocurrency Related Investment Products; Joint Statement by SEC and CFTC Enforcement Directors Regarding Virtual Currency Enforcement Actions - On January 18, 2018, in a...more
CFTC Issues Proposed Interpretation on Virtual Currency "Actual Delivery" in Retail Transactions - On December 15, 2017, the Commodity Futures Trading Commission ("CFTC") announced a Proposed Interpretation concerning its...more
SEC Announces the Formation and First Members of Fixed Income Market Structure Advisory Committee - On November 9, 2017, the Securities and Exchange Commission ("SEC") announced the formation and first members of its Fixed...more
SEC Proposes Rules to Implement FAST Act Mandate to Modernize and Simplify Disclosure - On October 11, 2017, the Securities and Exchange Commission (SEC) proposed amendments "to modernize and simplify disclosure...more
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
Federal Reserve and FDIC Post Resolution Plans for Eight Major Financial Firms - On July 5, 2017, the Federal Reserve Board (the "Board") and the Federal Deposit Insurance Corporation ("FDIC") posted the public portions of...more
Financial Industry Developments - Fee Rate Advisory #3 for Fiscal Year 2017 - On May 31, 2017, the Securities and Exchange Commission ("Commission") announced that starting July 4, 2017, the fee rates applicable to most...more
Financial Industry Developments - SEC Publishes Compliance and Disclosure Guidance for Regulation Crowdfunding - On April 5, 2017, the Division of Corporation Finance of the Securities and Exchange Commission...more
Financial Industry Developments - SEC Adopts Jobs Act Amendments - On April 5, the Securities and Exchange Commission ("SEC") announced that it has adopted amendments to increase the amount of money companies can...more
Financial Industry Developments - CFPB Proposes to Provide Flexibility in Collecting Information - On March 24, 2017, the Consumer Financial Protection Bureau ("CFPB") released a proposal to amend Equal Credit...more
Financial Industry Developments - SEC Adopts T+2 Settlement Cycle for Securities Transactions - On March 22, 2017, the Securities and Exchange Commission (SEC) adopted an amendment to Rule 15c6-1(a), shortening the...more
SEC Approves Rules to Ease Investor Access to Exhibits in Company Filings - On March 1, 2017, the Securities and Exchange Commission (SEC) voted to adopt rule and form amendments that will require issuers to include a...more
CFTC Indicates Willingness to Help Incubate Fintech - On February 21, 2017, J. Christopher Giancarlo, the acting chairman of the U.S. Commodity Futures Trading Commission ("CFTC"), has diverged from other U.S. federal...more
Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more
Financial Industry Developments - Federal Reserve Board Announces Finalized Rule Adjusting the Board's Maximum Civil Money Penalties - On January 18, 2017, the Federal Reserve Board announced that it was adjusting...more
With Fitch and DBRS [by most measures, the #3 and #4 rating agencies in a 3-player game] doling out AAA ratings for bonds backed by non-qualified mortgages that Moody’s has dubbed “risky.” Well worth keeping an eye on this...more