On February 15, 2023, the Securities and Exchange Commission (SEC) proposed new rules and amendments (Proposal) to Rule 206(4)-2 (Custody Rule) under the Investment Advisers Act of 1940 (Advisers Act)....more
A recurring “old chestnut” for those of you dealing with Cayman Islands segregated portfolio companies (SPCs) is the manner in which the segregation principles apply to segregated portfolios established by the SPC....more
As a further step towards the implementation of its security-based swap regime, the Securities and Exchange Commission (SEC) has adopted a number of long-awaited capital, margin and segregation requirements for security-based...more
The Securities and Exchange Commission (Commission) on December 11, 2015 proposed new Rule 18f-4 (Proposed Rule) under the Investment Company Act of 1940 (1940 Act) and amendments to certain proposed forms. The proposal...more
On October 31, the Commodity Futures Trading Commission issued a staff interpretation concerning its rules that oblige swaps dealers and major swap participants to send notices to their swap counterparties informing them of...more
Market participants that enter into uncleared swaps should expect to receive notifications from swap dealer (SD) and major swap participant (MSP) counterparties regarding segregation of initial margin for swaps. Dodd-Frank...more
On 23 December 2013, law decree n. 145 or the so-called Destinazione Italia decree ("Decree n. 145") was published in the Italian Official Gazette providing for certain changes to law n. 130 of 30 April 1999 ("Law 130" or the...more
By the end of this year, the European Commission will present its legislative proposals for EU banking structural reform. Once the proposals are implemented, EU banks will have to separate their “investment” business from...more
The Commodity Futures Trading Commission (CFTC or Commission) recently adopted several rules to improve large trader reporting, facilitate segregation of customer swap margin and enhance customer protections for futures and...more
On October 31, the Commodity Futures Trading Commission adopted final rules with respect to the segregation of initial margin for uncleared swaps. The rules impose new obligations on swap dealers (SDs) and major swap...more
In this issue: - CFTC Adopts Rules for Segregation of Initial Margin for Uncleared Swaps - CFTC Extends Time-Limited Relief for Foreign Exchange Swaps - CFTC Approves Position Limits Proposals -...more