Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
Key Takeaways - Following the SEC’s adoption, earlier this year, of changes to Form PF, large hedge fund advisers will face, for the first time, a requirement to report certain events to the SEC within 72 hours. ...more
After the 2008 financial crisis, the U.S. Securities and Exchange Commission (the “SEC” or “Commission”) introduced the Form PF (Private Fund), which the SEC intended to serve as a tool for monitoring and assessing systemic...more
To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more
On October 3, the Financial Stability Oversight Council (FSOC) released its “Report on Digital Asset Financial Stability Risks and Regulation” (Report), concluding, among other things, that unregulated cryptocurrencies could...more
The Financial Stability Oversight Council (“FSOC”) issued a document on October 21st titled: Report on Climate-Related Financial Risk 2021 (“Report”) The Report was issued in response to the Biden Administration’s Executive...more
There are less than two months before world leaders meet in Glasgow for the UN-sponsored Climate Change summit known as the Conference of the Parties (COP 26). This summer, we have been inundated with dire reports about...more
On April 14, 2021, the U.S. Senate confirmed the nomination of Gary Gensler as the 33rd Chair of the U.S. Securities and Exchange Commission (“SEC” or “Commission”). This change will bring forth a Democratic majority at the...more
In the News. The Consumer Financial Protection Bureau (CFPB), along with the Federal Trade Commission (FTC) and more than 50 federal and state law enforcement partners, announced Operation Corrupt Collector, a nationwide law...more
Editor's Note - In This Issue. The Securities and Exchange Commission (SEC) granted no-action relief for fund boards; the Financial Stability Oversight Council (FSOC) announced the rescission of the “systemically important...more
During the Trump Administration’s first year in office, it has implemented major new policy approaches and engaged in significant reversals of Obama Administration policies in many areas. In contrast, the Administration to...more
The U.S. Department of the Treasury (Treasury) recently released a report examining the regulatory framework for the asset management and insurance industries (Report). The Report is the third in a series of four reports that...more
As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more
On June 8, 2017, the House passed H.R. 10, the Financial “CHOICE” Act with a vote of 233 to 186. Introduced on April 27, 2017, the Financial CHOICE Act proposes to amend the Dodd-Frank Act to repeal the Volcker Rule,...more
Seyfarth Synopsis: Hours after the inauguration of President Trump, the White House issued a memorandum which imposed a 90-day delay on regulations which had not yet taken effect. As far as existing financial services law and...more
The election of Donald J. Trump as the 45th President of the United States, along with the Republican control of the majority of both the House of Representatives and the Senate, will likely result in significant changes in...more
House Financial Services Committee Votes To Repeal And Replace Dodd-Frank - On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010...more
On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010 Dodd-Frank law by a largely partisan vote of 30 to 26. Democrats declined to...more
Recently introduced legislation suggests that Republicans and Democrats in post-election Congress will be looking in very different directions on how to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act...more
Regulatory Developments - SEC Issues Order Approving Inflation Adjustments to “Qualified Client” Dollar Thresholds for Investment Adviser Performance Fee Rule - On June 14, the SEC issued an order approving...more
First, the Securities and Exchange Commission required funds to designate a chief compliance officer. Then, the SEC proposed that funds designate a liquidity risk manager, and after that, a derivatives risk manager. Can a...more
On June 7, 2016, House Financial Services Committee Chairman Jeb Hensarling (R-TX) released an executive summary of the Financial CHOICE Act (the “FCA”), his highly anticipated bill to revisit the Dodd-Frank Wall Street...more
House Financial Services Committee Chairman Jeb Hensarling (R-TX) unveiled details of the Financial CHOICE Act – the Republican plan to replace the Dodd-Frank Act and promote economic growth. CHOICE stands for Creating Hope...more
On April 18, 2016, the Financial Stability Oversight Council (FSOC) again warned that asset managers present systemic risk to financial stability in five key areas: ..liquidity and redemptions; ..leverage; ...more
July 21, 2015, marked the fifth anniversary of the signing of the landmark Dodd-Frank Act and provided a natural opportunity to evaluate the progress regulators have made in establishing the new regulatory regime as well as...more
Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more