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 March 12, 2025, the SEC published a No-Action Letter clarifying accredited investor verification requirements under Rule 506(c)....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
U.S. Developments - Regulatory Developments - SEC Issues Second No Action Letter for Blockchain-Based Project - On July 25, 2019, the staff of U.S. Securities and Exchange Commission (SEC) issued its second ever...more
An April 11, 2019, Office of Management and Budget Memorandum seeks to bring certain guidance issued by federal agencies, including the SEC, under more effective scrutiny. By its terms, the Memorandum applies to agency rules,...more
On April 8, 2019, Commissioner Hester Peirce of the Securities and Exchange Commission (“SEC”) delivered a speech entitled “SECret Garden” at the Practicing Law Institute’s 2019 SEC Speaks conference. In her speech,...more
Amid increasing enforcement activity with respect to cryptocurrencies, coins and tokens, the SEC recently issued guidance intended to provide clarity to the markets. ...more
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
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
The SEC chose a week that saw the price of Bitcoin spike by over $700 in an hour, kicking off a rally reminiscent of the go-go days of 2017, to issue its long-awaited “plain English” guidance for determining whether a digital...more
Wow, it finally happened. The SEC granted long awaited guidance on when tokens are not securities in the form of a no-action letter. ...more
On October 12, 2018, the Securities and Exchange Commission’s Division of Investment Management issued a no-action letter permitting a fund’s board of directors (“Board”) to rely upon quarterly compliance certifications...more
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
Division of Investment Management of the SEC Issues No-Action Letter to SSB - On May 8, 2018, the Chief Counsel's Office of the Division of Investment Management ("IM") of the Securities and Exchange Commission (the...more
Since 2014, many private company mergers and acquisitions intermediaries have chosen not to register as broker-dealers. That’s because a 2014 SEC no-action letter took the position that intermediaries that limited their...more