News & Analysis as of

New Guidance Interpretive Letters

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Wet...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a June 10th interpretive letter the application of Hazardous Materials Regulations (“HMR”) applicable to wet batteries...more

Orrick, Herrington & Sutcliffe LLP

OCC allows banks to use debt securities in repo agreements

On June 12, the OCC issued Interpretive Letter 1185 confirming that national banks may use certain debt securities as collateral in repurchase (repo) agreements. In the letter, the OCC responded to a December 19, 2024,...more

Jones Day

CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

Jones Day on

A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

Goodwin

SBA and Treasury Department Issue New Guidance on PPP

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) issued guidance on its authority to charter limited purpose trust companies, raising the possibility that a limited purpose national bank could be organized...more

BCLP

Securities and Corporate Governance Update – October 2019

BCLP on

This newsletter discusses noteworthy updates, key regulatory decisions and upcoming compliance reminders. In this edition, we review: ...SEC Changes Approach to Shareholder Proposal No-Action Requests ...SEC Issues...more

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