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
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
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
Earlier this month, the Consumer Financial Protection Bureau (CFPB or Bureau) issued new policy statements regarding its Compliance Assistance Sandbox (CAS) and No-Action Letters (NAL) programs. ...more
The US Consumer Financial Protection Bureau (CFPB) is giving no-action letters (NALs) a second chance. On January 8, 2025, the CFPB issued a policy statement setting forth new procedures for companies to request supervisory...more
On January 3, 2025, the Consumer Financial Protection Bureau (CFPB) announced a comprehensive reboot of its No-Action Letter (NAL) and Compliance Assistance Sandbox (CAS) policies. The proposed policies on its face, marks a...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
Join Bass, Berry & Sims and leading environmental, social, and governance (ESG) along with corporate and securities thought leaders for the next installment of our ESG Impact Webinar series. As public companies prepare for...more
Who may be interested: Closed-End Funds; Boards of Directors; Investment Advisers - Quick Take: The staff of the SEC’s Division of Investment Management (Staff) recently granted no-action relief to three closed-end funds...more
Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more
In Roth v. Foris Ventures, LLC, Nos. 22-16632, 22-16633, 2023 U.S. App. LEXIS 30081 (9th Cir. Nov. 13, 2023), the United States Court of Appeals for the Ninth Circuit partially reversed the dismissal of a shareholder...more
On July 21, 2023, a three-judge panel of the Fifth Circuit Court of Appeals issued an opinion asserting that the Commodity Futures Trading Commission’s Division of Market Oversight likely acted arbitrarily and capriciously,...more
Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more
The issue of when a person may be considered a “broker” or “dealer” and subject to registration as such under the federal securities laws, as distinguished from so-called finders (and therefore not subject to the panoply of...more
The year 2022 was a historic year for the Commodity Futures Trading Commission (“CFTC” or the “Commission”). Just four days into the new year, on January 4, 2022, Rostin Behnam was sworn in as the CFTC’s 15th Chairman. Three...more
The staff of the US Securities and Exchange Commission division of Investment Management announced that it would allow its October 26, 2017 no-action letter to SIFMA to expire on July 23, 2023—raising questions about the...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. Last year, Latham & Watkins sounded a hopeful note that 2020 would provide...more
At age 79, Paul Anka, the crooner and songwriter, is more relevant than ever. In 2020, he appeared on Season 4 of “The Masked Singer,” enjoyed a popular resurgence courtesy of TikTok, reworked his anthem “My Way” for the...more
In the News. Institutional Shareholder Services (ISS) published its proxy voting guidelines updates for 2021, which include new and updated voting recommendations on federal forum and exclusive forum provisions in companies’...more
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...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
The Staff of the Securities and Exchange Commission’s Division of Trading and Markets (Staff) issued a no-action letter to the Financial Industry Regulatory Authority on September 25, 2020 (Letter), in which the Staff stated...more
The staff (“Staff”) of the Division of Trading and Markets of the U.S. Securities and Exchange Commission (SEC) issued a no-action letter (NAL) at the request of the Financial Industry Regulatory Authority (FINRA) on...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
It was a year filled with tantalizing tidbits and many loose ends. 2019 marked the 10th year since blockchain technology was released into the wild by its still unknown inventor, Satoshi Nakamoto, who mined the first bitcoin...more