Regulation SE, the last of the Title VII Dodd-Frank rulemakings, will become effective on February 13, 2024. The Securities and Exchange Commission (SEC) has taken a significant step in enhancing the regulatory landscape...more
After issuing two proposals, the Securities and Exchange Commission (SEC) adopted final rules (Final Rules) to establish its trading regime for security-based swaps (SBS) as required under the Dodd-Frank Wall Street Reform...more
Revised deadlines for initial Schedule 13D and Schedule 13G filings: Schedule 13D: within five business days (rather than 10 calendar days) after crossing the 5% beneficial ownership threshold or losing eligibility to file...more
The Securities and Exchange Commission (SEC) is tasked with creating and enforcing regulations that safeguard investors, promote fair and transparent markets, and facilitate capital formation. Recently, the SEC revised Rule...more
In Short - The Situation: The civil action of the Commodity Futures Trading Commission ("CFTC") against Archegos Capital Management LP and its CFO is but one of many civil and criminal matters arising out of Archegos's...more
The Dodd–Frank Act continues to spawn new rules more than a decade after its passage. Our Financial Services & Products Group reviews a rule finalized 10 years after its proposal that protects security-based swaps from fraud...more
On February 9, the Federal Reserve released its hypothetical scenarios for its 2023 bank stress tests, and on February 10, the OCC also released hypothetical economic and financial market scenarios to be used by covered...more
As we have previously discussed, the SEC’s Fall 2022 “Reg Flex” Agenda charts the agency’s planned rulemaking through Q1 2023. Among this ambitious and wide-reaching agenda are two important final rulemakings concerning the...more
Gary Gensler served as Chair of the Commodity Futures Trading Commission (“CFTC”)from May 26, 2009 to January 3, 2014. He presided over the CFTC during the period that followed the 2008 financial crisis and led the CFTC...more
In Short - The Situation: In a federal district court complaint against Archegos Capital Management, LP ("Archegos"), the Commodity Futures Trading Commission ("CFTC") has asserted jurisdiction over what many view as...more
On Dec. 15, 2021, the U.S. Securities and Exchange Commission (SEC or Commission) proposed Rule 240.9j-1 (the Rule), intended “to prevent fraud, manipulation, and deception in connection with effecting transactions in, or...more
On December 15, the Securities and Exchange Commission (SEC) proposed a series of potentially far-reaching changes to the regulation of the security-based swap (SBS) markets. Among other changes, the proposed rules would...more
This client alert addresses three aspects of security-based swap (SBS) regulations recently issued by the Securities Exchange Commission (SEC) that are relevant to commercial end users, funds, and other financial end users:...more
Yesterday, for the first time as Chair of the Securities and Exchange Commission, Gary Gensler appeared before Congress to provide testimony regarding the market disruptions and volatility witnessed in January 2021 relating...more
REGULATORY UPDATES - SEC Proposes Conditional Exemption for Finders Assisting Small Businesses with Capital Raising - On October 7, 2020, the Securities Exchange Commission (the “SEC”) proposed a conditional exemption...more
The Commodity Futures Trading Commission (CFTC) voted to adopt new rules on position limits (Final Rules) in an open meeting on October 15. Once effective, the Final Rules will implement one of the remaining key provisions of...more
On December 18, 2019, the Securities and Exchange Commission (SEC) adopted a package of rule amendments, guidance and a related order to expand and improve the framework for regulating cross-border security-based swaps,...more
On December 18, 2019, the Securities and Exchange Commission (the SEC or Commission) adopted new rules pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) requiring the...more
On December 18, 2019, the SEC adopted certain rule amendments to enhance the framework for regulating cross-border security-based swaps. Through this effort, the SEC established a broad security-based swap regulatory regime...more
As a further step towards the implementation of its security-based swap regime, the Securities and Exchange Commission (SEC) has adopted a number of long-awaited capital, margin and segregation requirements for security-based...more
On September 19, the SEC adopted new rules and amendments under Title VII of the Dodd-Frank Act establishing recordkeeping and reporting requirements for security-based swap dealers and major security-based swap participants,...more
On June 21, the Securities and Exchange Commission (SEC) adopted new rules and rule amendments to establish capital, margin and segregation requirements under Title VII of the Dodd-Frank Act. ...more
Introduction - On May 10, 2019, the Securities and Exchange Commission (“SEC”) issued proposed rule amendments and interpretive guidance “to improve the framework for regulating cross-border security-based swaps...more
In recent days, the Securities and Exchange Commission (SEC) announced a no-action position on enforcing its 2016 Business Conduct Standards against security-based swap dealers (SBSDs) and major security-based swap...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) was signed into law eight years ago. ...more