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CFTC Operating and Enforcement Divisions Issue Advisory on Referrals to Enforcement Division

On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more

The CFTC is Off to a Fast Start Under Acting Chairman Pham

In a break from the typical acting agency chairman, Acting Commodity Futures Trading Commission ("CFTC") Chairman Caroline Pham has taken several significant actions, signaled several more, and set the agency on a path to...more

New CFTC Cooperation, Self-Reporting, and Remediation Enforcement Advisory Introduces Major Changes

The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more

The CFTC Finalizes Guidance on Voluntary Carbon Credit Contracts for Derivatives Markets

The Commodity Futures Trading Commission (“CFTC” or “Commission”) has inserted itself in recent years into efforts to scale the cash market for “high integrity” voluntary carbon credits. On September 20, 2024, the Commission...more

New York's LLC Transparency Act: What You Need to Know

On March 1, 2024, New York State Governor Kathy Hochul signed into law a revised version of New York State's LLC Transparency Act, which is modeled on FinCEN's Beneficial Ownership Information Rule. Other states are...more

FinCEN Issues Final Rule Extending Beneficial Ownership Information Reporting Deadline for New Entities

The Financial Crimes Enforcement Network ("FinCEN") has issued a final rule ("Final Rule") extending the initial reporting deadline for new entities required to file beneficial ownership information ("BOI") with FinCEN to 90...more

Preparing for Major Changes in FinCEN Beneficial Ownership Reporting

An estimated 32.6 million domestic and foreign companies will soon be required to report information about their beneficial owners to the U.S. Treasury. This White Paper describes the new requirements and the steps companies...more

Medical Payment Products and Health Care Pricing Practices Draw CFPB Attention

The Consumer Financial Protection Bureau (“CFPB”), Department of Health and Human Services (“HHS”), and United States Treasury have issued an interagency Request for Information (“RFI”) focused on the offering and provision...more

Litigation and Regulatory Considerations and Risks for Financial Market Participants in a Post-Pandemic Society

More than a year ago the world fell victim to a global pandemic that would change life in ways that could never have been predicted. In the early stages of the pandemic, we published a White Paper directed at financial...more

Stay of Execution Proposed for USD LIBOR

ICE Benchmark Administration Limited ("IBA") upends market expectations by announcing a consultation on an 18-month extension for most tenors of USD LIBOR. IBA announced on November 30, 2020, that it would launch a market...more

FCA Consultation on New Benchmark Powers Highlights Ongoing Discussions Regarding USD LIBOR

The Situation: On the same day that the ICE Benchmark Administration ("IBA") launched a consultation on its intention to cease publishing euro, sterling, Swiss franc, and yen LIBOR at year-end 2021, the UK Financial Conduct...more

UK Financial Services Bill Includes New Powers for FCA to Manage LIBOR Transition

The proposed powers for the Financial Conduct Authority ("FCA") to manage the London Interbank Offered Rate ("LIBOR") transition should address so-called "tough legacy" contracts involving UK participants but could also have...more

FINRA Shares LIBOR Transition Preparation Practices of Broker-Dealers - FINRA has published helpful survey results on the...

On August 5, 2020, FINRA published Regulatory Notice 20-26, summarizing the results of a survey FINRA conducted of a representative cross-section of member firms, including firms with significant trading volumes or positions...more

Latest Developments in Dealing With "Tough Legacy" IBOR Transition Contracts

The United Kingdom and European Union look to give powers to regulators, rather than using direct legislation, to deal with existing contracts that prove unable to convert or be amended to include fallbacks ahead of IBOR...more

SEC Staff Announces Initiative on LIBOR Transition

The Situation: The SEC's Office of Compliance Inspections and Examinations ("OCIE") intends to examine registrants to assess preparation for the expected discontinuation of LIBOR and the transition to alternative reference...more

Back to the Well: ARRC Seeks Market Input on Simplifying Spread Adjustment Calculation

The Development: The Alternative Reference Rates Committee ("ARRC") announced the results of its market consultation on the "spread adjustment" calculation for the LIBOR/SOFR transition on May 6, 2020, but found it necessary...more

ISDA Announces Results of "Final Parameters" Consultation for LIBOR Transition - A two business-day "lag" period and five-year...

The International Swaps and Derivatives Association, Inc. ("ISDA") has announced the results of its "Final Parameters" Consultation (the "Consultation") on a number of important mechanical details and specifications for...more

ISDA Pre-Cessation Trigger Consultation on LIBOR Renders Inconclusive Verdict

The Situation: The International Swaps and Derivatives Association ("ISDA") is in the midst of consulting the market on a wide variety of issues to develop "triggers" and "fallbacks" related to LIBOR cessation. Thus far,...more

Mandatory Summer Reading: SEC Staff Issues Rare Joint Statement on LIBOR Transition

The Situation: The Staffs of the Divisions of Corporation Finance, Investment Management and Trading and Markets ("Divisions") of the U.S. Securities and Exchange Commission ("SEC") and its Office of the Chief Accountant...more

ISDA Forges Ahead With Market Consultations on Critical IBOR Transition Issues

Two new consultations seek market input on USD and other currencies and on inclusion of "non-representativeness" trigger - The International Swaps and Derivatives Association, Inc. ("ISDA") launched two additional IBOR...more

Compare and Contrast: SFIG's and ARRC's Differing Approaches to Benchmark Transition in Securitizations

The Situation: SFIG's LIBOR Task Force has released the first of a planned series of "green papers" on benchmark transition in the US securitization market. The Result: The Green Paper contains proposed recommendations...more

ISDA Publishes Results of Benchmark Fallbacks Consultation as Sunset Looms for LIBOR

The Situation: The International Swaps and Derivatives Association, Inc. ("ISDA") has announced the preliminary results of its market consultation concerning the fallbacks rates to be relied on upon cessation of certain...more

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