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No-Action Letters Disclosure Requirements Financial Services Industry

Davis Wright Tremaine LLP

CFTC Eliminates PTMMM Disclosure Requirements for Swap Entities

On April 4, 2025, the CFTC's Division of Market Participants issued No-Action Letter 25-09 regarding the controversial Pre-Trade Mid-Market Mark ("PTMMM") requirements in CFTC Regulation 23.431, effectively eliminating the...more

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

Morrison & Foerster LLP

Back to the Future: SEC Staff Issues Sweeping New Guidance on Shareholder Proposals Mid-Season

On February 12, 2025, the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) published Staff Legal Bulletin No. 14M (SLB 14M), rescinding Staff Legal Bulletin No. 14L (Nov. 3, 2021)...more

Goodwin

CFPB To Revisit Trump-Era QM Final Rules

Goodwin on

In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more

Hudson Cook, LLP

CFPB Bites of the Month - November Top 10

Hudson Cook, LLP on

Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the CFPB to be considered by financial services providers. In this month's article, we share our top "bites" covered during...more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

Goodwin on

In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more

Ballard Spahr LLP

CFPB finalizes product sandbox proposal and changes to trial disclosure, no-action letter policies; discloses plans to propose...

Ballard Spahr LLP on

The CFPB has finalized its proposed revisions to its Policy to Encourage Trial Disclosure Programs” (TDP Policy) and policy on “no-action” letters (NAL Policy) and has also finalized its proposal to create a new “product...more

Ballard Spahr LLP

CFPB clarifies coverage of “disclosure sandbox” proposal; consumer groups comment on proposed revisions to no-action letter policy...

Ballard Spahr LLP on

“Disclosure Sandbox.”  In September 2018, the Bureau proposed significant revisions to its “Policy to Encourage Trial Disclosure Programs” which sets forth the Bureau’s standards and procedures for exempting individual...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

FHFA Issues Final Rule on Fannie Mae and Freddie Mac Duty to Serve Underserved Markets - On December 13, 2016, the Federal Housing Finance Agency (FHFA) issued a final rule implementing the Duty to Serve provisions...more

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