The focus on quantifying LIBOR exposure and related disclosure requirements may be a ‘red herring.’ The real issues are (i) whether the LIBOR transition is merely an excuse to change the effective interest rates of financial...more
The Sixth Circuit Court of Appeals dismissed a suit by the Tennessee, Georgia and New York Republican parties challenging the constitutionality of an MSRB extending pay-to-play prohibition to municipal advisors. The Court...more
Regulatory Developments - FINRA Files Proposed Rule Change to Apply Markup Rule to Government Securities: On Sept. 30 FINRA filed with the SEC a proposed rule change, published in the Federal Register on Oct. 6, to...more
The Municipal Securities Rulemaking Board (“MSRB”) announced September 2 that it has submitted for SEC approval proposed amendments extending its gift-limitations Rule G-20 to municipal advisors. In general, the Rule...more
The Securities Exchange Commission announced June 18 the first major wave of underwriter sanctions under its Municipalities Continuing Disclosure Cooperation (“MCDC”) Initiative. The SEC sanctioned 36 municipal underwriting...more
The Commission recently filed an amicus brief defending its Dodd-Frank whistleblower rules. Those rules specify that the anti-retaliation provisions of those amendments to the Exchange Act protect those who chose not to...more
The Impact of Regulation on Community Banks: Harvard Study and Senate Banking Committee Hearing Highlight Differing Views. FDIC Director of Risk Management Supervision Doreen Eberley testified last week before the Senate...more
The SEC announced July 8 its first settled administrative proceeding against a municipal issuer under its Municipal Continuing Disclosure Cooperation (“MCDC”) Initiative. In its Order, the SEC charged Kings Canyon Joint...more
On May 19, 2014, the SEC issued an updated set of FAQs on the rule defining and requiring municipal advisors to register with the SEC (the Rule). The updated FAQs provide clarification on several important issues for certain...more
The SEC Office of Municipal Securities has issued interpretive guidance to address questions from market participants regarding the implementation of new final SEC rules requiring municipal advisors to register with the SEC. ...more
Participants in the municipal securities market should take particular interest in the appointment of Elisse B. Walter as chair of the SEC. Her close association with regulation of the municipal securities market makes it...more