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

For the first time, the CFTC has fined a company for poor cybersecurity practices that resulted in a third-party breach of the company’s information systems.  This development is consistent with an increasing trend of regulators holding companies responsible for the cybersecurity failures of third-party service providers.

AMP Global Clearing LLC … Read More

In his recent speech that we have covered in a series of blog posts, Federal Reserve Vice Chair for Supervision Randal Quarles announced that he would like the Federal Reserve to achieve “meaningful simplification of our framework of loss absorbency requirements,” referring to both the Federal Reserve’s capital and … Read More

The Financial Stability Board, Basel Committee on Banking Supervision, Committee on Payments and Market Infrastructures and International Organization of Securities Commissions announced late last week a survey focusing on the effects of post-crisis regulatory reforms on incentives to centrally clear over-the-counter (OTC) derivatives.

The G20 agreed in 2009 to promote … Read More

Six years after finalizing the first set of Basel III reforms to the capital framework for banking organizations, the Basel Committee on Banking Supervision has agreed on and released the final set of revisions to the Basel III capital standards (sometimes referred to as “Basel IV”).

The reforms include the … Read More

The Federal Reserve Board announced today that it will continue its policy of not deploying the countercyclical buffer (CCyB), a decision it reached after assessing the considerations in its September 2016 CCyB policy statement and consulting with the FDIC and OCC.

The CCyB is a macroprudential policy tool that the … Read More

CFTC Chairman Giancarlo testified this morning that he intends to delay for an additional year a decision on whether to modify the currently effective swap dealer de minimis registration threshold of $8 billion notional of dealing swaps.[1] This request follows on the heels of a recommendation by the U.S. Treasury, … Read More

The Office of the Comptroller of the Currency (the “OCC”) took a first formal step in evaluating how the regulations implementing the Volcker Rule should be revised by issuing a request for public input on the regulations in early August, with comments due in late September.  Of the 55 comment … Read More

Wednesday, October 11, 2017
12:00 pm – 1:00 pm ET

Register for Webcast

Please join us for a discussion on the evolving law and practice on the document management aspects of cyber security, including:

  • Regulators’ expectation for companies regarding deleting old non-public data to reduce cyber risk.
  • The interactions between
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There has been significant attention to the first major policy speech by the CFTC’s newly-minted Enforcement Division Director, James McDonald on September 25, 2017.  Mr. McDonald’s speech outlined the Enforcement Division’s updated approach to self-reporting and cooperation, as described in an enforcement advisory update issued to coincide with his speech … Read More

The U.S. banking agencies this week released a proposal that would significantly amend the U.S. Basel III capital rules of all three agencies by simplifying the capital treatment of several items, primarily for non-advanced approaches banking organizations.  The proposed rule represents the agencies’ next step in the agencies’ efforts, discussed … Read More