News & Analysis as of

No-Action Letters Enforcement Actions Regulatory Oversight

Troutman Pepper Locke

The CFPB Issues Revised Sandbox and No-Action Letter Policies

Troutman Pepper Locke on

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

Carlton Fields

Fifth Circuit Breaks From No-Action Pack: Becomes Better Bet for Letter Recipients?

Carlton Fields on

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

Perkins Coie

Blockchain Week in Review - April 2019

Perkins Coie on

U.S. Developments - Regulatory Updates - SEC Releases “No-Action Letter” Stating Turnkey Jet ICO Tokens Are Not Securities and Releases “Framework for ‘Investment Contract’ Analysis of Digital Assets” - The U.S....more

Jones Day

SEC Issues Framework for Digital Assets and Grants First No-Action Relief to Token Issuer

Jones Day on

The Situation: The U.S. Securities and Exchange Commission ("SEC") issued a framework for market participants in assessing whether their digital assets-related activities involve the offer, sale, or distribution of investment...more

Kramer Levin Naftalis & Frankel LLP

SEC Staff Allows Boards to Rely on CCO Determinations for Various Affiliated Transactions

In a no-action letter (the Relief) issued on Oct. 12, 2018, to the Independent Directors Council, the Securities and Exchange Commission staff (the Staff) confirmed that they would not recommend enforcement if a fund’s board...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

Polsinelli on

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

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