The Federal Reserve yesterday announced the opening of the registration process, and issued registration instructions and revised FAQs, for its Commercial Paper Funding Facility (CPFF), originally announced on March 17, 2020, expanded on March 23, 2020 and further detailed in initial FAQs on March 25, 2020. 
Continue Reading Fed Opens Registration Process for Commercial Paper Funding Facility

The business and financial fallout of the coronavirus pandemic is hitting companies in all areas of the U.S. economy, and weighing on those from industry giants to small local businesses. For many businesses, survival will depend on accessing one or more of the numerous support programs announced by the Federal
Continue Reading Introducing Davis Polk’s Government Support for Business Resource

The SEC recently proposed amendments to the current market data infrastructure to expand the content required to be published on the consolidated tape and decentralize the collection, consolidation, and dissemination of market data through the introduction of proposed competing consolidators and self-aggregators.

Please see our client memorandum for more details.
Continue Reading SEC Proposes Changes to Market Data Infrastructure

Congress passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) this afternoon, and we cover it here in two memos. In one memo, we cover the economic stabilization, small business and bank regulatory sections of the legislation. In the other memo, we cover tax
Continue Reading Congress Passes the CARES Act: Economic Stabilization and Tax Relief

The Federal Reserve has issued updated FAQs regarding its money market mutual fund liquidity facility (MMLF), modifying the FAQs issued on March 21.

For more information on the MMLF, please see our memorandum and blog post describing the original MMLF announced on March 18, our blog post describing
Continue Reading Fed Updates FAQs for the Money Market Mutual Fund Liquidity Facility

The CFTC unanimously approved final interpretive guidance describing what constitutes “actual delivery” of a virtual currency for purposes of the actual delivery exception from the provisions of the Commodity Exchange Act that prohibit any leveraged, margined, or financed transaction in a commodity with a retail customer, unless the transaction is
Continue Reading CFTC Adopts Final Interpretation on the Actual Delivery Exception for Leveraged Retail Virtual Currency Transactions

The Federal Reserve has issued FAQs providing more information about its Commercial Paper Funding Facility (CPFF), originally announced on March 17, 2020 and expanded on March 23, 2020 as part of its response to the coronavirus crisis.  The FAQs provide additional details on how the CPFF will work,
Continue Reading Fed Issues FAQs for Commercial Paper Funding Facility

Following our initial post on the Bank of England’s (the “Bank”) Covid Corporate Financing Facility (“CCFF”), the Bank has published further details, including full terms and conditions of participation and application forms for prospective issuers and banks acting on behalf of companies.

If, after speaking with their respective banks, prospective
Continue Reading The Bank of England Releases Further Details on its Covid Corporate Financing Facility and ICMA Makes Euro Commercial Paper Materials Publicly Available

The Federal Reserve announced on March 23, 2020 further action in response to the coronavirus crisis: the creation of the Secondary Market Corporate Credit Facility (SMCCF), along with establishment of the Primary Market Corporate Credit Facility (PMCCF) and the Term Asset-Backed Securities Loan Facility (TALF). We discuss the
Continue Reading Fed Creates Secondary Market Corporate Credit Facility to Provide Liquidity to Corporate Bonds

The Federal Reserve announced on March 23, 2020 further action in response to the coronavirus crisis: the creation of the Primary Market Corporate Credit Facility (PMCCF), along with the Secondary Market Corporate Credit Facility (SMCCF) and the Term Asset-Backed Securities Loan Facility (TALF). We discuss the SMCCF and
Continue Reading Fed Establishes the Primary Market Corporate Credit Facility to Support Credit to Employers