Thomson Reuters Session 1: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?
Carbon Quarterly is a newsletter covering developments in carbon policy, law, and innovation. No matter your views on climate change policy, there is no avoiding an increasing focus on carbon regulation, resiliency planning,...more
The first in-person ISDA annual general meeting (“AGM”) after the COVID-19 pandemic is wrapping up today in Madrid, Spain. This conference follows the Futures Industry Association Law and Compliance (“FIA L&C”) annual...more
Snidely Whiplash kidnaps Nell and, in the show’s opening, ties her to the railroad tracks to get even with his nemesis, Dudley Do-Right, of the famed Royal Canadian Mounted Police. Menacing music plays. In each episode,...more
This client alert addresses three aspects of security-based swap (SBS) regulations recently issued by the Securities Exchange Commission (SEC) that are relevant to commercial end users, funds, and other financial end users:...more
As part of the ongoing transition from the London InterBank Offering Rate (LIBOR) to the Secured Overnight Financing Rate (SOFR) recommended by the Alternative Reference Rates Committee (ARRC) as an alternative rate, an...more
On March 15, 2021, ISDA published the ISDA 2021 Security-Based Swaps (SBS) Top-Up Protocol (the SBS Top-Up Protocol). The SBS Top-Up Protocol enables SBS dealers (SBSDs) and other market participants to comply with certain...more
The United Kingdom’s Financial Conduct Authority announced the future cessation and loss of representativeness of worldwide LIBOR rates. Potential Detrimental Developments - Recent Events - On Friday, March 5,...more
On November 30, 2020, parties to legacy LIBOR contracts breathed a collective sigh of relief as LIBOR’s administrator Intercontinental Exchange, Inc. (“ICE”) announced that US Dollar LIBOR would continue to be published until...more
BROKER-DEALER - SEC and CFTC Chairman Issue Joint Letter Regarding CFTC Orders Implicating Regulations A and D - On October 23, Chairman Jay Clayton of the Securities and Exchange Commission and Chairman Heath P....more
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
BROKER-DEALER - FINRA Requests Comments for Proposed Amendments to FINRA Rule 2165 - On October 5, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 20-34, which requests comment on proposed...more
SEC/CORPORATE - SEC Stays Implementation of New NYSE Direct Listing Rules - As discussed in the August 31, 2020 edition of the Corporate & Financial Weekly Digest, on August 26, the Securities and Exchange Commission...more
BROKER-DEALER - FINRA Proposes Rule Change to Temporarily Amend Certain Timing, Method of Service and Other Procedural Requirements in FINRA Rules - On May 8, the Financial Industry Regulatory Authority (FINRA) filed...more
The outbreak of the COVID-19 coronavirus is causing business disruption on an unprecedented scale. After more than a decade of sustained economic growth, market volatility and central bank intervention has returned. ...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) released a policy statement outlining framework that the CFPB will immediately begin to apply in matters of supervision and enforcement regarding the “abusive”...more
Regulators are increasing pressure on financial institutions to demonstrate that they are proactively addressing the transition away from LIBOR. On December 23, 2019, the New York State Department of Financial Services...more
For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...more
The Situation: The International Swaps and Derivatives Association ("ISDA") is in the midst of consulting the market on a wide variety of issues to develop "triggers" and "fallbacks" related to LIBOR cessation. Thus far,...more
As a continuation of our previous update on the phase-out of the London Interbank Overnight Rate (“LIBOR”) (April 30, 2019: What the LIBOR Phase-out Means for Debt Capital Market Participants), the Securities and Exchange...more
On July 12, 2019, the U.S. Securities and Exchange Commission (SEC) joined the call to prepare for the transition away from LIBOR. The staff of several Divisions of the SEC (the Divisions of Corporation Finance (DCF),...more
The Situation: The Staffs of the Divisions of Corporation Finance, Investment Management and Trading and Markets ("Divisions") of the U.S. Securities and Exchange Commission ("SEC") and its Office of the Chief Accountant...more
The U.S. Commodity Futures Trading Commission, U.S. Securities and Exchange Commission and the U.K. Financial Conduct Authority have issued a joint statement regarding the use of "opportunistic strategies" in the credit...more
BROKER-DEALER - SEC Adopts Rules and Interpretations To Enhance Protections and Preserve Choice for Retail Investors - On June 5, the Securities and Exchange Commission voted to adopt a package of rules and...more
BROKER-DEALER - SEC Chairman Clayton and Trading and Markets Director Redfearn Call for a Reassessment of Regulation NMS - On March 8, US Securities and Exchange Commission chairman Jay Clayton and director, Division...more
The US Department of Justice vehemently opposed the request for a new trial by the first person charged, convicted and sentenced under the Dodd-Frank Wall Street Reform and Consumer Protection Act’s prohibition against...more