News & Analysis as of

Securities and Exchange Commission (SEC) No-Action Letters Financial Services Industry

Katten Muchin Rosenman LLP

After 12 Enforcement Actions and 9 No-Action Letters, CFTC Staff Effectively Repeals the Pre-Trade Mid-Market Mark Disclosure...

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

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

Carlton Fields

Expect Focus - Volume III, September 2023

Carlton Fields on

Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Mayer Brown Free Writings + Perspectives

SEC Staff Grants Temporary Relief from Compliance with Rule 15c2-11 for Rule 144A Fixed Income Securities

With the January 3, 2023, deadline fast approaching for compliance with Exchange Act Rule 15c2-11, as amended and reinterpreted by the staff of the US Securities and Exchange Commission (“SEC”) to apply to fixed income...more

Cadwalader, Wickersham & Taft LLP

Rule 15c2-11 Update: The SEC Provides Temporary Relief for Fixed Income Rule 144A Securities Until January 4, 2025

The SEC’s Division of Trading and Markets issued a new no-action letter yesterday that removes the requirement that Rule 144A information be made publicly available prior to a broker-dealer publishing a quotation or...more

Goodwin

House Votes to Repeal OCC True Lender Rule

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In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more

Goodwin

CFPB To Revisit Trump-Era QM Final Rules

Goodwin on

In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more

Goodwin

ISS Publishes 2021 Proxy Voting Guidelines

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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

Morrison & Foerster LLP

New Life For Finders?

Background- For many years, small businesses and other private issuers have struggled to connect with investors when seeking to raise capital in a private offering. The amount of money being raised was sometimes too small...more

Goodwin

Financial Services Weekly Roundup: OCC Adds “Madden Fix” To Its Playbook

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In This Issue. The Office of the Comptroller of the Currency (OCC) finalized its “Madden fix,” establishing a rule that codifies the “valid when made” principle for nationally chartered banks; the Securities and Exchange...more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

Goodwin on

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

Goodwin

Financial Services Weekly News: Regulators Prepare for End of LIBOR

Goodwin on

I’m Dreaming of . . . LIBOR Cessation and Transition. While many of us were enjoying the holiday season, federal and state financial regulators were focused on the transition away from the London Interbank Offered Rate...more

Polsinelli

Wind of Change - The Year FinTech Came in From the Cold - Polsinelli BitBlog: Year End Edition

Polsinelli on

Digital assets and Blockchain technologies which were once described as the tools of criminals, are now a key part of efforts by traditional financial services firms to transform their businesses and innovative firms looking...more

Morrison & Foerster LLP

Financial Services Report, Fall 2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Carlton Fields

Use of Non-Binding SEC Staff Guidance Called Into Question

Carlton Fields on

Recent moves by the SEC could signal a shift away from the use of non-binding guidance in the form of no-action letters or other types of compliance and interpretive information that the SEC staff frequently publishes....more

Goodwin

Financial Services Weekly News - March 2018 #3

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Editor's Note - D.C. Circuit Strikes Down Key Pieces of FCC’s TCPA Interpretive Order. On March 16, the U.S. Court of Appeals for the D.C. Circuit issued its long-awaited decision in ACA International v. FCC, invalidating...more

Goodwin

Financial Services Weekly News - January 2018 #3

Goodwin on

Editor's Note - “Humility and Prudence” at the CFPB. In a memo to employees of the Consumer Financial Protection Bureau (CFPB) later turned into a Wall Street Journal op-ed, Acting CFPB Director Mick Mulvaney articulated his...more

Goodwin

Financial Services Weekly News - March 2017 #4

Goodwin on

Editor's Note - The Battle Over the Proposed OCC FinTech Charter Continues. The Office of the Comptroller of the Currency (OCC) has released a draft supplement to its Licensing Manual explaining the process for FinTech...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

FHFA Issues Final Rule on Fannie Mae and Freddie Mac Duty to Serve Underserved Markets - On December 13, 2016, the Federal Housing Finance Agency (FHFA) issued a final rule implementing the Duty to Serve provisions...more

Goodwin

Financial Services Weekly News - November 2016

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Editor's Note Voting Matters. Next week, we head to the polls to elect a new president of the United States and other government representatives. Voting is important because it allows registered citizens to cast their...more

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