Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
On April 21, the Financial Stability Oversight Council (FSOC) released a proposed analytic framework for financial stability risks, “intended to provide greater transparency to the public about how [FSOC] identifies,...more
This latest edition of the regulatory initiatives paper sets out at a high level the core regulatory issues that are likely to impact private fund managers in the coming months, including an overview of the key actions needed...more
On December 17, 2021, the Financial Stability Oversight Council (“FSOC”) – a collaborative body formed under the Dodd-Frank Act composed of state and federal regulators and tasked with identifying risks and responding to...more
As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more
The National Association of Insurance Commissioners (NAIC) held its 2019 Spring National Meeting from April 5 through 9 in Orlando, Florida. This meeting was distinguished by a very large class of new commissioners (15 in...more
Treasury Secretary Steven Mnuchin testified before the US Senate Committee on Banking, Housing, & Urban Affairs at the committee’s Financial Stability Oversight Council annual report to Congress hearing. In his prepared...more
Cybersecurity threats are the biggest challenge facing the financial services industry, the Financial Stability Oversight Council (FSOC) declared in its annual report, calling on federal regulators to ensure that banks are...more
The National Association of Insurance Commissioners (NAIC) held its 2017 Fall National Meeting from December 2 through December 4 in Honolulu, Hawaii. Despite the exotic locale, the Fall National Meeting was not as well...more
On December 14, the Financial Stability Oversight Council (FSOC), which was established by the Dodd-Frank Act to analyze and mitigate potential threats to the financial sector, released its first report under the Trump...more
President Trump campaigned on reversing many Obama-era policies, and he is making good on his promises. The uncertainty of which major regulatory changes are in the pipeline is certainly keeping the legal community on its...more
The National Association of Insurance Commissioners (NAIC) met in Philadelphia, Pennsylvania for the 2017 Summer National Meeting from August 5-9. Commissioners, staff and interested parties alike converged in Philadelphia...more
The NAIC’s 2016 Annual Report is titled, “Inspiring Innovation” and the themes of innovation and the new capabilities that technology offers were evident throughout the weekend. In March, the NAIC announced the creation of a...more
Election Day brought an end to a long period of uncertainty that caused market fluctuations and delayed business planning decisions. As we navigate the post-election landscape, many questions remain regarding the potential...more
In June 2016, the Financial Stability Oversight Council (“FSOC” or the “Council”) released its Annual Report. The Council discussed the continued “pressing concern” of cyber threats and vulnerabilities and also focused on...more
On June 24, 2016, in a response letter to Senator Dean Heller (R-NV), Daniel Tarullo, a member of the Board of Governors of the Federal Reserve System, highlighted the benefits of consistent cybersecurity supervisory...more
An annual report from the Financial Stability Oversight Council (FSOC) recently focused on the risks presented by the burgeoning fintech industry as well as the continuing "pressing concern" of cyber threats and...more
In a keynote address before the Investment Company Institute on May 20, 2016, SEC Chair Mary Jo White signaled to the Financial Stability Oversight Counsel (FSOC) that the SEC is “working hard” to finalize rules that address...more
Several industry associations jointly published a paper titled International Cybersecurity, Data and Technology Principles and urged the Financial Stability Board and the International Organization of Securities Commissions...more
Regulatory Developments - DOL Issues Final Fiduciary Rule - On April 6, the Department of Labor (DOL) unveiled its pre-publication final version of the long-awaited fiduciary rule (the Final Rule). Some of the more...more
Non-Recognition of US CCPs as Subject to Equivalent Regulation May Require European-Based Funds to Restrict Trading in US Centrally Cleared Derivatives - An opinion by the European Securities and Markets Authority...more