Podcast: CFTC Issues LIBOR Transition Relief for Swaps
LEGAL ALERT: CFPB Issues Proposed Revisions to No-Action Letter Policy
Open for Business: SEFs Navigate the New Regulatory Environment
The European Banking Authority has published a no-action letter in response to the European Commission's postponement of the application of the revised market risk framework, also known as the Fundamental Review of the...more
In November 2020, the CFTC published two no-action letters extending previously granted no-action relief related to Brexit. The relief was intended to provide “greater certainty to the global marketplace” in connection with...more
On October 26, 2017, the SEC staff issued a no-action letter providing relief to broker-dealers that provide research that constitutes “investment advice” under the Investment Advisers Act of 1940 to investment managers...more
The U.K. Financial Conduct Authority has welcomed the U.S. Securities and Exchange Commission’s extension of no-action relief addressing a potential conflict between U.S. regulation and the inducements and research provisions...more
The Commodity Futures Trading Commission has issued two no-action letters to ensure that existing regulatory relief and substituted compliance measures for EU firms will continue to apply to U.K. firms following the U.K.’s...more
In this issue, we examine the release of the much-anticipated Strategic Hub for Innovation and Financial Technology (FinHub) guidance for analyzing how U.S. federal securities laws apply to initial coin offerings, the...more
The Commodity Futures Trading Commission ("CFTC") extends no-action and exemptive relief from the European Union to the United Kingdom. On April 5, 2019, the CFTC's Divisions of Clearing and Risk, Market Oversight and Swap...more
BROKER-DEALER - Nasdaq Proposes Rule Change to SEC to Assume Operational Responsibility for Certain Investigation and Enforcement Functions Currently Performed by FINRA - On April 3, the Securities and Exchange...more
New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes New Fund-of-Funds Rule – On December 19, 2018, the SEC proposed new Rule 12d1-4 under the Investment Company Act of 1940, which, if...more
Division of Investment Management of the SEC Issues No-Action Letter to SSB - On May 8, 2018, the Chief Counsel's Office of the Division of Investment Management ("IM") of the Securities and Exchange Commission (the...more
BROKER-DEALER - FINRA Requests Comment on Proposed New Rule Governing Outside Business Activities On February 26, the Financial Industry Regulatory Authority released Regulatory Notice 18-08, which solicits comments on...more
On October 26, 2017, the Securities and Exchange Commission ("SEC" or the "Commission") staff issued three no-action letters to help broker-dealers, investment advisers and investment companies comply with the European...more
Unbundling research and execution costs for money managers subject to MiFID II means that US broker-dealers can expect to receive hard dollars or other separately identified payments for research, at least from EU managers....more
New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more
On October 26, 2017, the staff (the Staff) of the U.S. Securities and Exchange Commission (SEC) issued three related no-action letters providing market participants with greater clarity as to how certain aspects of their...more
A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details on SEC’s no action letters and Commission’s FAQs on “hard dollar” research payments under...more
FHFA Updates Progress on Fannie Mae and Freddie Mac Credit Risk Transfer Programs - On July 26, 2017, the Federal Housing Finance Agency released an update on the credit risk transfer programs of Freddie Mac and Fannie Mae...more
FHFA Issues Final Rule on Fannie Mae and Freddie Mac Duty to Serve Underserved Markets - On December 13, 2016, the Federal Housing Finance Agency (FHFA) issued a final rule implementing the Duty to Serve provisions...more
Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more
SEC/CORPORATE - SEC Publishes Concept Release Regarding Business and Financial Disclosure - On April 13, the Securities and Exchange Commission published a concept release, recommended by the SEC’s Division of...more
Bureau of Consumer Financial Protection Issues Policy on No-Action Letters - On February 18, the Consumer Financial Protection Bureau issued a new policy statement on No-Action Letters. Under the Policy, Bureau...more
BROKER-DEALER - FINRA Requests Information Regarding Firm Culture and Values - The Financial Industry Regulatory Authority is requesting firms to submit information regarding their organizational culture and how...more
SEC/CORPORATE - SEC Advisory Committee on Small and Emerging Companies to Discuss Capital Formation Landscape for Small and Emerging Companies - The Securities and Exchange Commission announced that its Advisory...more
The Restructuring Mid-Summer Review: Europe and the Emerging Markets - For those focused on the debt restructuring market, the Greek sovereign crisis (covered extensively in our recent updates1) has drowned out news of...more
RMBS Claims Against Ratings Agencies Dismissed as Time-Barred - On March 27, Judge John Robert Blakely of the U.S. District Court for the Northern District of Illinois granted Standard & Poor's Financial Services, LLC's...more