On May 2, 2013, the SEC filed an order instituting settled administrative proceedings against the trustees (“Trustees”) and certain service providers of two “turnkey” open-end series investment companies, Northern Lights Fund...more
Two recent district court decisions have shed light on the reach and scope of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign nationals: SEC v. Straub and SEC v. Sharef. For companies and individuals operating...more
The Jumpstart Our Business Startups Act, or JOBS Act, was designed to facilitate capital-raising transactions by smaller companies, including private companies. A likely but less heralded consequence of the JOBS Act is that...more
On August 29, 2012, the Securities and Exchange Commission (“SEC” or the “Commission”) proposed rules to implement section 201 of the Jumpstart Our Business Startups Act (the “JOBS Act”).1 The JOBS Act directed the SEC to...more
Introduction - On July 18, 2012, the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC” and, together with the SEC, the “Commissions”) jointly published several final rules...more
On September 10, 2012, the CFTC issued rules mandating new record-keeping and registration requirements for swap dealers and major swap participants in the $700 trillion derivative global market. The rules were published in...more
Dear Clients and Friends: In October, federal agencies proposed two new sets of regulations under the Dodd-Frank Act. The proposals — to implement the Volcker Rule and to create standards to designate certain nonbanks...more
TABLE OF CONTENTS I. Who Does the Dodd-Frank Act Impact? ...1 A. Major Swap Participants...1 1. Category 1: Substantial Position in Swap Categories ...1 2. Category 2: Substantial Counterparty Exposure...more
Discussion Topics •General Overview of the Dodd-Frank Act •Title VII of the Dodd Frank Act: Impact on OTC Derivatives and Energy Trading •Definitions and applicability •Mandatory clearing •Registration...more
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