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SEC "Gift" to the Industry: Four Market Structure Proposals, 3-2 Votes (In Part), but No Partridge in a Pear Tree

On December 14, 2022, the SEC proposed four separate equity market structure rulemakings, each of which, if adopted, will have significant effects on the markets and various industry participants. While designed to address...more

SEC Publishes Spring Rulemaking Agenda: Torrid Pace Continues; Crypto Framework Noticeably Absent

On June 22, 2022, the U.S. Securities and Exchange Commission (“SEC” or “the Commission”) released its Spring 2022 "Reg Flex" agenda. The regulatory agenda, set by Chairman Gary Gensler, provides a glimpse into how the agency...more

Ding, Dong! The Dealer/Trader Distinction is Dead. HFTs and DEX AMMs Should Take Notice

The SEC recently proposed rules that would greatly expand the Exchange Act definition of “dealer” and essentially kill the existing dealer/trader distinction long-recognized by the SEC. The likely outcome is that most...more

SEC Focus on Cybersecurity Begins to Take Shape

The U.S. Securities and Exchange Commission is implementing a campaign to overhaul the agency’s expectations around cybersecurity and cyber incident reporting for the financial services industry and corporate America...more

SEC Proposes Broad Expansion of Regulation ATS, Regulation SCI, and Exchange Definition

On January 26, 2022, the SEC proposed rule changes that would greatly expand the scope of Regulation ATS, the regulatory regime that governs alternative trading systems (“ATSs”). The proposal focuses on four main...more

SEC Proposes Rules That Could Regulate DeFi, Extend to Aspects of Centralized Crypto Exchanges

On January 26, 2022, the SEC proposed rule changes that would greatly expand the scope of Regulation ATS, the regulatory regime that governs alternative trading systems (“ATSs”). Applicability to the fixed income markets was...more

SEC Proposes Securities Lending Transaction Reporting Requirements

On November 18, 2021, the U.S. Securities and Exchange Commission proposed new Rule 10c-1, which, if adopted, would create a new reporting and disclosure framework for the securities lending market. Rule 10c-1 would require...more

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