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Surviving Swings – A Derivatives and Trading Watch List

Recent market disruptions have resulted in reports of margin calls in amounts unseen since 2020. Those reports have turned the spotlight on derivatives, repos and other transactions. The significant role these products play...more

Treasury Clearing Rule: Compliance Date Extensions, Temporary Relief and FICC Implementation

An overview of the recent SEC action to extend the compliance dates for rules requiring submission for central clearing of certain Treasury repo transactions. An overview of the temporary exemption providing relief to...more

Addressing Questions Under the Amended Registered Fund Names Rule

Recent amendments to Rule 35d-1 under the Investment Company Act of 1940 —commonly known as the “Names Rule” — broaden the scope of terms in fund names subject to the rule, impose enhanced disclosure and compliance...more

SEC Finalizes Changes to Dealer Definition – Does Not Exempt Private Funds or Proprietary Trading Firms

At a contentious open meeting on February 6, 2024, the Securities and Exchange Commission (Commission) voted three to two to adopt rule amendments (Final Rules) under the Securities Exchange Act of 1934, as amended (Exchange...more

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