U.S. Developments - Federal and State Regulatory Developments - U.S. Department of Homeland Security Issues Challenge for Development of Trusted User Interface for Digital Wallets - The U.S. Department of Homeland Security...more
The U.K. Financial Conduct Authority has welcomed the U.S. Securities and Exchange Commission’s extension of no-action relief addressing a potential conflict between U.S. regulation and the inducements and research provisions...more
The extension benefits market participants in the US seeking to comply with EU MiFID II research rules, but significant issues remain. Key Points: ..The no-action relief has been extended for three additional years from...more
On November 4, 2019, the Office of the Chief Counsel of the SEC's Division of Investment Management extended the temporary no-action relief from compliance with the registration and other provisions of the Investment Advisers...more
The Commodity Futures Trading Commission ("CFTC") extends no-action and exemptive relief from the European Union to the United Kingdom. On April 5, 2019, the CFTC's Divisions of Clearing and Risk, Market Oversight and Swap...more
Relief issued by the US Commodity Futures Trading Commission resolves any doubts that UK firms, as well as their swap counterparties and affiliates, may have had about whether no-action relief would continue to apply to UK...more
BROKER-DEALER - Nasdaq Proposes Rule Change to SEC to Assume Operational Responsibility for Certain Investigation and Enforcement Functions Currently Performed by FINRA - On April 3, the Securities and Exchange...more
BROKER-DEALER - Postponement of Margin Rules for Covered Agency Transactions Under FINRA Rule 4210 - The Financial Industry Regulatory Authority is filing a rule change (SR-FINRA-2019-005) with the Securities and...more
DERIVATIVES - SEC Issues Statement on Swap Business Conduct Rules - On October 31, the Securities and Exchange Commission took an unusual additional step towards implementing its rules for security-based swaps (SBS) by...more
On October 26, 2017, the Securities and Exchange Commission ("SEC" or the "Commission") staff issued three no-action letters to help broker-dealers, investment advisers and investment companies comply with the European...more
FHFA Updates Progress on Fannie Mae and Freddie Mac Credit Risk Transfer Programs - On November 22, 2017, the Federal Housing Finance Agency ("FHFA") issued a status report on credit risk transfer transactions done in...more
CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements - On November 14, 2017, the U.S. Commodity Futures Trading Commission's Division ("CFTC") of Market...more
New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more
BROKER-DEALER - FINRA Releases New Targeted Exam Letter Regarding Order Routing Conflicts - On November 10, the Financial Industry Regulatory Authority released the contents of a new Order Routing Conflicts targeted...more
On October 26, 2017, the staff (the Staff) of the U.S. Securities and Exchange Commission (SEC) issued three related no-action letters providing market participants with greater clarity as to how certain aspects of their...more
SEC/CORPORATE - SEC Division of Corporation Finance Issues C&DI Clarifying Exemptions for Non-GAAP Information in Forecasts for M&A Transactions - On October 17, the staff of the Securities and Exchange Commission’s...more
SEC/CORPORATE - Implementation of Pay Ratio Disclosure Requirement Not Expected to Be Delayed - On September 15, at the ABA Business Law Section Annual Meeting, the Securities and Exchange Commission (SEC) Division of...more
CME and LCH Amend Rulebooks on Variation Margin - Market participants historically have characterized cleared derivatives as being "collateralized-to-market", treating variation margin transfers as daily collateral...more
CFTC - CFTC Extends Previously Granted No-Action Relief for Swap Dealers Complying With EU Requirements - On April 18, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight...more
SEC/CORPORATE - SEC Adopts Technical Amendments to JOBS Act Rules On March 31, the Securities and Exchange Commission adopted technical amendments to rules adopted by the SEC under the Jumpstart Our Business...more
On February 23, 2017, U.S. federal banking regulators (Prudential Regulators), European regulators and the International Organization of Securities Commissions (IOSCO) issued statements clarifying their expectations on...more
SEC/Corporate - SEC Releases Rule 504 Small Entity Compliance Guide for Issuers - The Securities and Exchange Commission recently released a Small Entity Compliance Guide for Issuers, which provides a brief summary...more
SEC/CORPORATE - President-Elect Trump Nominates Clayton as SEC Chair - On January 4, President-elect Donald Trump announced his nomination of Jay Clayton to serve as chair of the Securities and Exchange Commission,...more
SEC/CORPORATE - SEC Division of Corporation Finance Issues 35 New C&DIs Regarding Foreign Private Issuers, QIBs and Offshore Offerings - On December 8, the staff (Staff) of the Securities and Exchange Commission’s...more
Financial Industry Developments - Special Purpose National Bank Charters for FinTech Companies - On December 2, 2016, Comptroller of the Currency, Thomas J. Curry, announced that the Office of the Comptroller of the...more