In the second part of this legal update series, we summarize the key takeaways from the Division of Examinations’ (Division) 2025 priorities report released on October 21, 2024. The Division remains focused on mainstays like...more
On October 21, 2024, the Securities and Exchange Commission’s (SEC) Division of Examinations (the Division) published its annual examination priorities for 2025 (2025 Priorities), which focus on certain “practices, products,...more
On October 16, 2023, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) published its annual Examination Priorities for 2024 (the “Exam Priorities”). Consistent with the...more
The SEC shortened Schedule 13D and Schedule 13G beneficial ownership reporting deadlines and amended disclosure requirements. The SEC modified and accelerated the initial filing and amendment deadlines, as well as...more
On October 10, 2023, the Securities and Exchange Commission adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934. The adopting release...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 SEC recently adopted new recordkeeping requirements for broker-dealers and “SBS entities” (security-based swap dealers and major security based swap participants). Most notably, the SEC will no longer require...more
Compliance Today (May 2022) - Would a law that makes it illegal to mislead the chief compliance officer (CCO) help or hinder the mission of the compliance function? We may find out, albeit on a very limited scale, if one...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 July 13 2016, the US Securities and Exchange Commission (SEC) adopted amendments and guidance (Final Rules and Guidance) related to its rules on the regulatory reporting and public dissemination of security-based swaps...more
More than six years after the enactment of the Dodd-Frank Act, and more than three years after the US Commodity Futures Trading Commission (CTFC) required swap dealers to register in accordance with Title VII of that Act, it...more
Early this month the U.S. Securities and Exchange Commission (“SEC”) released final rules (the “Registration Rules”) for the registration of security-based swap dealers (“SBSDs”). The Registration Rules, released more than...more
SEC Adopts Registration Rules for Security-Based Swap Entities - On August 5, 2015, the SEC adopted rules and forms governing the registration process for security-based swap dealers and major security-based swap...more
On September 8, the Securities and Exchange Commission proposed a rule providing that publication or distribution of quotes involving security-based swaps that may be purchased only by eligible contract participants would not...more
In this issue: - Bylaw of Delaware Corporation Providing for Exclusive Forum in North Carolina Upheld - FINRA Board to Consider Rule Proposals Regarding Private Trading Platforms - CBOE and C2 in...more
In this issue: - ISS Launches New Equity Plan Data Verification Portal - ISDA Publishes Protocol for 2014 Credit Derivatives Definitions - FinCEN Issues Advisories for US Financial Institutions -...more
On Wednesday, June 25, 2014, the Securities and Exchange Commission (the "SEC") issued new rules and guidance regarding cross-border security-based swap activities for market participants. The SEC issued the new rules as part...more
The SEC has proposed recordkeeping and reporting rules and capital charges for security-based swap dealers based on the current broker-dealer reporting and recordkeeping regime. Market participants in the derivatives...more