Mr. Rosenberg is a partner in Davis Polk’s Financial Institutions Group. [Full Bio]

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.
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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
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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
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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,
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The Federal Reserve has created a new secured liquidity facility, called the Term Asset-Backed Securities Loan Facility (TALF), designed to restore liquidity to the asset-backed securities (ABS) market.  TALF represents a continuation of the Federal Reserve’s use of its “unusual and exigent” powers to help provide
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The CFTC today joined other U.S. financial regulators in providing COVID-19 related relief from certain regulatory requirements. This relief is designed to help CFTC-registered swap dealers, futures commission merchants (FCMs), introducing brokers, swap execution facilities (SEFs), designated contract markets (DCMs) and other market participants
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On December 18, 2019, the CFTC proposed rules that would modify and codify the cross-border application of certain of its Title VII swap rules to both U.S. and non-U.S. registered swap dealers and major swap participants.  Among other changes, these proposed rules would revise (1) which cross-border swaps must be
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On January 30, 2020, the Federal Reserve Board, OCC, FDIC, SEC and CFTC (the Agencies) proposed amendments to the covered fund provisions of the Volcker Rule. The proposed amendments address long-standing concerns with the over-broad definition of covered fund, the treatment of foreign funds (both public and private), and the
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In a step forward for the digital transformation of banking and partnerships between banks and FinTechs, the FDIC released proposed changes to its brokered deposit regulations in late December 2019. The proposed changes are designed to update the regulatory framework as much as possible within the constraints of the existing
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The Financial Stability Oversight Council’s (FSOC) recently revised guidelines (the 2019 Guidelines) on how it will identify and address financial stability risks are a major shift from the guidelines it issued in the immediate aftermath of the Financial Crisis.  The 2019 Guidelines draw upon lessons learned from
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