News & Analysis as of

Disclosure Requirements Securities and Exchange Commission (SEC) Financial Institutions

Katten Muchin Rosenman LLP

After 12 Enforcement Actions and 9 No-Action Letters, CFTC Staff Effectively Repeals the Pre-Trade Mid-Market Mark Disclosure...

The Commodity Futures Trading Commission's (CFTC or Commission) Market Participants Division (MPD) issued Letter 25-09, which effectively eliminates the pre-trade mid-market mark (PTMMM) disclosure requirement for uncleared...more

A&O Shearman

SEC expands confidential review of registration statements

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The SEC recently announced new accommodations to expand the types of companies and registration statements eligible for confidential SEC review. In this post, we summarize key takeaways from the announcement, including what...more

Seward & Kissel LLP

SEC Charges Investment Advisers for Compliance Failures Relating to Cash Sweep Programs

Seward & Kissel LLP on

Quick Take: Indicative of a recent SEC focus on bank deposit sweep programs (BDSPs) offered to advisory clients through broker-dealers, the SEC recently settled charges against three dually registered investment advisers and...more

Foley Hoag LLP

SEC Announces One Year Delay in Filing Obligations under Rule 13f-2 and Corresponding Form SHO

Foley Hoag LLP on

On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted Rule 13f-2 and related Form SHO pursuant to the Securities Exchange Act of 1934. Rule 13f-2 requires that any party meeting the definition of...more

Mayer Brown Free Writings + Perspectives

SEC Grants Temporary Exemption from Rule 13f-2 and Form SHO Compliance

On February 7, 2025, the US Securities and Exchange Commission (SEC) provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and the associated Form SHO reporting. Originally, the...more

Mayer Brown Free Writings + Perspectives

ICI Urges SEC to Delay Short-Sell Reporting Rules Amid Compliance Uncertainty

The Investment Company Institute (ICI) has asked the Securities and Exchange Commission (SEC) in a comment letter to delay enforcement of its new short sale disclosure rules (the “Short Sale Final Rules”) until additional...more

Seward & Kissel LLP

2025 SEC Filing Deadlines and Financial Statement Staleness Dates

Seward & Kissel LLP on

2025 desk top reference for public companies: the attached document includes a 2025 calendar and other resources to help alert public companies to key SEC filing dates and financial statement staleness deadlines....more

Fenwick & West LLP

SEC rescinds SAB 121 - What it Means for Financial Institutions and Crypto Exchanges

Fenwick & West LLP on

On January 23, 2025, the Securities and Exchange Commission (SEC) issued Staff Accounting Bulletin 122 (SAB 122), rescinding the controversial SAB 121....more

Ropes & Gray LLP

Updated SEC Staff Accounting Bulletin Rescinds SAB 121 Crypto Accounting Guidance

Ropes & Gray LLP on

On January 23, 2025, President Trump signed an executive order titled Strengthening American Leadership in Digital Financial Technology (Crypto EO), which addressed a variety of crypto-related topics to the great relief of...more

WilmerHale

SEC Approves FINRA Rules to Establish Securities Lending Reporting Facility

WilmerHale on

On January 2, 2025, the Securities and Exchange Commission (SEC) approved the FINRA Rule 6500 Series (the SLATE Rules), which establishes the Securities Lending and Transparency Engine (SLATE), a new facility for the...more

Morrison & Foerster LLP

SEC Caps 2024 with Another Cyber Enforcement Action

The SEC continues to leave its mark as a federal cybersecurity enforcer and closed out the year by charging another company with making misleading statements about a cybersecurity attack and failing to maintain cyber-related...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Short Sale Reporting Due by February 14, 2025

The Securities and Exchange Commission (SEC) adopted new Exchange Act Rule 13f-2 and related Form SHO on October 13, 2023, which requires certain institutional investment managers (Managers) to report short-sale information...more

Skadden, Arps, Slate, Meagher & Flom LLP

California Seeks Public Input on Climate Reporting Requirements

On December 16, 2024, the California Air Resources Board (CARB) issued a request to solicit feedback regarding Senate Bill 253, Climate Corporate Data Accountability Act (SB 253) and Senate Bill 261, Greenhouse Gases:...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update October – November 2024

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The following summarizes recent legal developments of note affecting the mutual fund/investment management industry. On October 21, 2024, the SEC Division of Examinations (“EXAMS”) published its annual Examination Priorities...more

Proskauer - Regulatory & Compliance

Launch of the Taskforce on Inequality and Social-related Financial Disclosures

The Taskforce on Inequality and Social-related Financial Disclosures (“TISFD”) launched on 23 September 2024. Background - The TISFD is a global initiative with the aim of developing recommendations and guidance for...more

Mintz - ML Strategies

2024 Pre-Election Analysis: Financial Services

Mintz - ML Strategies on

Financial services encompass a wide range of services offered by the nation’s financial institutions, including banking, mortgage, investment, and credit services. The next administration and Congress’s financial services...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2024 #4

Troutman Pepper Locke on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

K&L Gates LLP

Global Survey of ESG Regulations for Asset Managers - ESG and the Sustainable Economy Handbook

K&L Gates LLP on

INTRODUCTION - Asset managers (i.e., investment advisers) offering funds in more than one country are accustomed to adapting to different regulatory requirements. However, the challenges presented by the global regulation...more

Baker Donelson

[Webinar] New Privacy and Cybersecurity Regulations: What Financial Institutions Need to Know to Stay Compliant - June 13th, 10:00...

Baker Donelson on

The financial services industry has seen a litany of new data privacy and cybersecurity challenges through the first half of 2024. Financial institutions are facing unprecedented compliance hurdles resulting from the...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 31: The Road Ahead for Financial Services Data Privacy Regulation

Orrick Partner Beth McGinn joins RegFi co-hosts Jerry Buckley and Sasha Leonhardt for our second episode focused on the proposed American Privacy Rights Act and its potential impact on the financial services industry. Beth...more

K&L Gates LLP

March 2024 ESG Policy Update—Australia

K&L Gates LLP on

Australian Update - Australian Securities and Investments Commission Continues Greenwashing Enforcement Efforts - On 28 February 2024, the Australian Securities and Investments Commission (ASIC) reported that an outsourced...more

Ballard Spahr LLP

SEC Adopts Rules to Enhance and Standardize Climate-Related Disclosure

Ballard Spahr LLP on

The Securities and Exchange Commission (SEC) adopted rules expanding climate-related disclosure requirements in annual reports and registration statements for U.S. public companies and foreign private issuers. The final...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Jones Day

The Climate Report | First Quarter 2024

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The U.S. Securities and Exchange Commission has adopted much anticipated climate-related disclosure rules....more

Spilman Thomas & Battle, PLLC

Decoded - Technology Law Insights, V 5, Issue 2, March 2024

HHS Cybersecurity Performance Goals and the Healthcare Industry - The healthcare industry is a major target for cyberattacks because of all of the personal information collected from patients. Recognizing that the healthcare...more

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