News & Analysis as of

No-Action Letters Regulatory Requirements Compliance

Cadwalader, Wickersham & Taft LLP

Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures

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

Flaster Greenberg PC

SEC Offers Updated Guidance for Rule 506(c) Private Placements

Flaster Greenberg PC on

On March 12, 2025, the SEC published a No-Action Letter clarifying accredited investor verification requirements under Rule 506(c)....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

Mayer Brown

New Action on No-Action Letters – CFPB Begins Accepting Applications Under Updated No-Action Letter Procedures

Mayer Brown on

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

Sheppard Mullin Richter & Hampton LLP

CFPB Updates No-Action Letter and Compliance Assistance Sandbox Policies to Spur Innovation

On January 3, 2025, the CFPB announced a reboot of its no-action letter and compliance assistance sandbox policy, aimed at promoting consumer-beneficial innovation in financial services. The new policies are designed to...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Illusory Promise or Real Change? Transition at CFTC Brings Hope for Dodd-Frank Act Revisions

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

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