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
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
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
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
On October 12, 2022, the Securities and Exchange Commission (SEC or Commission) voted to adopt amendments to the electronic recordkeeping requirements for broker-dealers and security-based swap dealers contained in Rules...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
The US Securities and Exchange Commission proposed new rules on December 15, 2021, with respect to security-based swaps that, if adopted as proposed, would prohibit fraud and manipulation, require reporting of large...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more
As of November 1, 2021, dealers in security-based swaps (“SBS”) whose dealing activity exceeds certain de minimis thresholds (e.g., gross notional amount of $3 billion for credit default SBS, $150 million for other SBS, and...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
Unless otherwise exempted, entities engaging in SBS dealing activity in the immediately preceding 12 months, as of the Counting Date and thereafter, must register as an SBS dealer if the SBS positions connected with its SBS...more
The CFTC has adopted a final rule to prohibit the controversial practice of post-trade name give-up for swaps that are executed anonymously through a Swap Execution Facility (SEF) and are intended to be cleared. Although the...more
The Securities and Exchange Commission (SEC) security-based swap dealer (SBSD) rules have finally been issued, and a large amount of work will be required to comply. The good news is there is a foundation to build on, given...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 September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major...more
BROKER-DEALER - SEC Issues Guidance on Substituted Compliance Applications by Non-US Security-Based Swap Dealers and Major Security-Based Swap Participants - On November 25, the Securities and Exchange Commission’s...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
The Securities and Exchange Commission (SEC) continues to take steps toward implementation of its security-based swap (SBS) dealer registration framework. A particular area of concern for market participants has been how the...more
In this issue of Structured Thoughts, we discuss: ..The SEC’s newly released margin rules for security-based swap dealers. ..U.K.’s Financial Conduct Authority consultation on its proposal to ban the sale, marketing, and...more
On June 21, 2019, the Securities and Exchange Commission (SEC or Commission) adopted a package of rules and rule amendments (Rules) that set forth the capital, margin and segregation requirements for security-based swap...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
SEC/CORPORATE - SEC Adopts Additional Rules for Security-Based Swaps - On June 21, the Securities and Exchange Commission adopted a panoply of final rules dealing with the following aspects of the regulation of...more