News & Analysis as of

No-Action Relief Regulatory Oversight

Sullivan & Worcester

The War is Over: the SEC Won

Sullivan & Worcester on

On November 18, 2019, the Chairman of the Commodities and Futures Trading Commission (“CFTC”), Heath Tarbert, sat for an interview on digital assets and did something we have never seen before. He declared the winner of the...more

Carlton Fields

SEC Expands Manager-of-Managers Relief to Affiliated Sub-Advisers

Carlton Fields on

On May 29, 2019, the SEC granted an exemptive order to Carillon Series Trust and Carillon Tower Advisers Inc. (a Raymond James affiliate) to hire and replace affiliated and unaffiliated sub-advisers without shareholder...more

Orrick - On the Chain

The SEC’s Second No-Action Relief for Digital Tokens: Meaningful Relief or a Wolf in Sheep’s Clothing?

Orrick - On the Chain on

Pocketful of Quarters, Inc. (PoQ) is the second-ever recipient of no-action relief from the Division of Corporation Finance of the Securities and Exchange Commission for the issuance of “Quarters.” Quarters are a digital...more

Jones Day

SEC Issues Framework for Digital Assets and Grants First No-Action Relief to Token Issuer

Jones Day on

The Situation: The U.S. Securities and Exchange Commission ("SEC") issued a framework for market participants in assessing whether their digital assets-related activities involve the offer, sale, or distribution of investment...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

Polsinelli on

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more

Katten Muchin Rosenman LLP

CFTC Extends Continued No-Action Relief From Certain Recordkeeping Requirements

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and Division of Market Oversight (collectively, Divisions) have issued CFTC Letter No. 15-65, which indefinitely extends the...more

Katten Muchin Rosenman LLP

CFTC Extends No-Action Relief to Certain Affiliated Counterparties

On November 17, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) and Division of Clearing and Risk (DCR) each extended no-action relief for certain affiliated counterparties....more

Orrick - Finance 20/20

CFTC Announces Further Extension of Time-Limited No Action Relief

Orrick - Finance 20/20 on

On October 14, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight (the “Division”) announced further extension of the time-limited no action relief for swaps executed as part of a package...more

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