Federal Reserve Issues Policy Statement on Section 9(13) of the Federal Reserve Act - On January 27, the Federal Reserve issued a policy statement interpreting section 9(13) of the Federal Reserve Act, which authorizes...more
The final rules for implementing Section 941 of the Dodd-Frank Act as it relates to credit risk retention will become effective December 24 of this year. With the effective date quickly approaching, Congress has stepped in to...more
In February 2014, the Securities and Exchange Commission (SEC) once again re-opened the comment period with respect to proposed revisions to Regulation AB relating to the disclosure of asset-level data after receiving many...more
On December 10, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity...more
In two interpretive letters issued on October 11, 2012 (collectively, the “Interpretive Letters”), the Division of Swap Dealers and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the...more
Perhaps one of the most important questions since the Dodd-Frank Act is “What is a commodity pool”? Close behind is “Who is a commodity pool operator”? The CFTC has begun to shed light on these questions by issuance of...more
Dear Clients and Friends: In October, federal agencies proposed two new sets of regulations under the Dodd-Frank Act. The proposals — to implement the Volcker Rule and to create standards to designate certain nonbanks...more