Seven months after our initial note on the subject, the United States Securities and Exchange Commission (the SEC) on November 27, 2023 adopted Rule 192 (Rule 192 or the Final Rule)1 pursuant to Section 27B of the Securities...more
On January 25, 2023, the United States Securities and Exchange Commission (the SEC) revived a proposed rule (initially proposed in September 2011) pursuant to Section 27B (Proposed Rule 192) aimed at preventing material...more
3/14/2023
/ ABS ,
Asset-Backed Securities ,
Conflicts of Interest ,
Liquidity ,
Proposed Rules ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Transactions ,
Securitization ,
Underwriting
On November 30, 2022, the Staff (Staff) of the Division of Trading & Markets of the Securities and Exchange Commission (the SEC) issued a no-action letter (the November 2022 NAL) (extending relief from the requirements of...more
On January 30, 2020, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission and the Commodity...more
On February 9, 2018, the U.S. Court of Appeals for the District of Columbia Circuit Court (the “Court”) issued a significant decision in the case of Loan Syndications & Trading Ass’n v. SEC, No. 17-5004, --- F.3d ---, 2018 WL...more
U.S. regulation of money managers, including non-U.S. managers, and the funds they manage is a complex regime that has changed significantly since the implementation of the Dodd-Frank Reform and Consumer Protection Act of...more
6/18/2015
/ Broker-Dealer ,
Capital Formation ,
Dodd-Frank ,
Exemptions ,
Financial Regulatory Reform ,
Foreign Investment Fund ,
Investment Adviser ,
Investment Management ,
JOBS Act ,
Licensing Rules ,
Volcker Rule