This week’s update includes, among other key items, the FSB’s report on its evaluation of the effects of too-big-to-fail reforms for systemically important banks. This report, alongside the FSB’s report on Covid-19 support...more
Recent regulatory developments of interest to financial institutions and markets. Includes the extension of the senior managers regime to benchmark administrators, updates relating to MiFID II, EMIR, ESMA's draft guidelines...more
CFTC Issues Proposed Interpretation on Virtual Currency "Actual Delivery" in Retail Transactions - On December 15, 2017, the Commodity Futures Trading Commission ("CFTC") announced a Proposed Interpretation concerning its...more
SEC Announces the Formation and First Members of Fixed Income Market Structure Advisory Committee - On November 9, 2017, the Securities and Exchange Commission ("SEC") announced the formation and first members of its Fixed...more
Commencing on 1 January 2018, European and non-European entities or persons producing or selling packaged retail investment and insurance-based products (so-called PRIIPs) to retail investors in Europe, will be required under...more
Agencies Propose Simplifying Regulatory Capital Rules - On September 27, 2017, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the Office of the Comptroller of the Currency announced a proposed...more
On Jan. 3, 2018, the long-anticipated overhaul of European Union (EU) financial markets legislation will come into effect. The second Markets in Financial Instruments Directive (MiFID II) will broaden the scope of EU...more
On September 26, 2017, the European Commission published Delegated Regulation (C(2017) 6337 final), which it has adopted to amend Delegated Regulation (EU) 2017/571, which supplements MiFID II Directive (2014/65/EU) with...more
Key developments in April 2017: 3 April - The FCA published its Consultation Paper on persistent debt and earlier intervention remedies, “Reforming the availability of information in the UK equity IPO process”...more
SEC Rolls Out “POSITIER” - The SEC’s Office of the Investor Advocate used a recent March 9, 2017 open meeting and related “Evidence Summit” to announce its new investor research initiative, “POSITIER.”1 This new acronym...more
On March 31, 2017, 28 Delegated Regulations supplementing the Markets In Financial Instruments Directive (“MiFID II“) (2014/65/Eu) and the Markets in Financial Instruments Regulation (Regulation 600/2014) (“MiFIR“) were...more
Financial Industry Developments - CFPB Proposes to Provide Flexibility in Collecting Information - On March 24, 2017, the Consumer Financial Protection Bureau ("CFPB") released a proposal to amend Equal Credit...more
SEC Approves Rules to Ease Investor Access to Exhibits in Company Filings - On March 1, 2017, the Securities and Exchange Commission (SEC) voted to adopt rule and form amendments that will require issuers to include a...more
AIFMD - ESMA Updates Q&As on the Application of the AIFMD - ESMA updated its Q&As on 16 December on the application of the AIFMD. The revised Q&As include one updated question and answer on reporting obligations by...more
Financial Industry Developments - CTFC Approves Re-Proposal of Position Limits Regulation - On December 5, 2016, the U.S. Commodity Futures Trading Commission ("CFTC") unanimously approved to re-propose rules that...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
The European Securities and Markets Authority published a discussion paper on the trading obligation for derivatives under the Markets in Financial Instruments Regulation. The trading obligation is applicable to classes of...more
The European Parliament voted to object to draft regulatory technical standards (“RTS”) implementing the Packaged Retail and Insurance Investment Products (PRIIPs) Regulation (the “Regulation”) on 14 September 2016. The draft...more
EMIR – Exemption for Danish Pension Schemes and Endorsement of Margin Requirements for Uncleared Derivatives - ESMA issued its opinion exempting certain Danish pension scheme from central clearing under EMIR on 3 August...more
Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements - On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office...more
On June 29, 2016, the European Commission adopted a Delegated Regulation supplementing the MiFID II Directive with regard to regulatory technical standards (RTS) specifying information to be notified by investment firms,...more
FHFA Requests Input on Credit Risk Transfer Transactions - On June 29, 2016, the Federal Housing Finance Agency published a report outlining its perspective on the credit risk transfer programs of Fannie Mae and Freddie...more
On June 8, 2016, the European Commission adopted the following two Delegated Regulations supplementing the MiFID II Directive (2014/65/EU): 1. A Delegated Regulation (C(2016) 3333 final) in relation to regulatory...more
The European Commission adopted a Delegated Regulation on Regulatory Technical Standards on the authorization and organizational requirements for, and publication of transactions by, Data Reporting Services Providers. The...more
The European Commission adopted a Delegated Regulation on RTS setting out the standards for non-discriminatory access for central counterparties and trading venues to licenses of, and information relating to, benchmarks. The...more