Podcast: CFTC Issues LIBOR Transition Relief for Swaps
LEGAL ALERT: CFPB Issues Proposed Revisions to No-Action Letter Policy
Open for Business: SEFs Navigate the New Regulatory Environment
The staff of the US Securities and Exchange Commission’s Division of Corporation Finance recently granted no-action relief for transactions under Securities Act Rule 192(a)(3)(iii) (commonly known as prong (iii)) where the...more
On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called...more
On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more
Regulatory Announcements - CFPB Issues No Action Letter to Facilitate Consumer Access to Loans. The Consumer Financial Protection Bureau (CFPB) issued a No-Action Letter to Bank of America, N.A. on November 5 regarding...more
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
Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more
In addition to releasing a finalized No-Action Letter (NAL) Policy, the Consumer Financial Protection Bureau (CFPB) also issued a revised Trial Disclosure Policy and Compliance Assistance Sandbox Policy on September 10....more
Bank, nonbank, and Fintech providers of consumer financial products and services may be able to reduce their exposure to compliance risk under the December 13, 2018 No Action Letter (“NAL”) Policy changes proposed by the...more
In recent days, the Securities and Exchange Commission (SEC) announced a no-action position on enforcing its 2016 Business Conduct Standards against security-based swap dealers (SBSDs) and major security-based swap...more
On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more
Dear clients and friends, We present our traditional year-end issue of Snell & Wilmer’s Corporate Communicator to help you prepare for the upcoming annual report and proxy season. This issue highlights SEC reporting and...more
Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...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
On March 7, 2016, the Consumer Financial Protection Bureau (CFPB) announced that it will begin collecting complaints from consumers about online marketplace lenders, signaling its intention to increasingly regulate the...more
Much of Director Cordray’s testimony in his appearance before the Senate Banking Committee yesterday consisted of his predictable defense of various CFPB positions. While the hearing was much less contentious than last...more
The Consumer Financial Protection Bureau (Bureau) issued its final policy on its issuance of no-action letters on February 18, which is intended to further objectives under section 1021 of the Dodd-Frank Wall Street Reform...more
On January 8, 2016, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Clearing and Risk (DCR) issued a no-action letter (CFTC Letter 16-01) providing relief from the clearing requirement for some swaps...more
This Glossary is designed to provide law students taking Securities Regulation with a tool that will assist them in learning the basic language of securities law and achieve a working knowledge of the fundamental principles...more
The letter modifies previous No-Action Letter 13-22, to expand relief for treasury affiliates entering into swaps on behalf of non-financial end-user affiliates that could otherwise elect the exception in section 2(h)(7) of...more
On November 26, CFTC issued a no-action letter providing additional relief for eligible treasury affiliates that enter into swaps that are subject to the clearing requirement in section 2(h)(1) of the Commodity Exchange Act...more
In This Issue: - RECENT CASES .. Mortgage Servicing Rules .. Antiretaliation Provision ..Credit Default Swaps Antitrust Litigation ..CFPB Involvement in Litigation - IN THE...more
The CFPB has issued a proposed policy where it would issue no-action letters in limited circumstances. The proposed policy is designed for new financial products or services where there may be uncertainty about how they fit...more
Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more
The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) recently addressed for the first time the CFTC’s definition of a “swap” as it applies to a specific insurance...more
In this issue: - Proposed Amendments to Delaware General Corporation Law and Courts and Judicial Procedure Law - SEC Division of Corporation Finance Issues New C&DIs Relating to Social Media Use - FINRA...more