Jai R. Massari

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Ms. Massari is a partner in Davis Polk's Financial Institutions Group and the trading and markets practice, based in the Washington DC office. [Full Bio]

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The Federal Reserve has taken temporary measures (and has published FAQs) to (1) lift the net debit cap on and waive fees for daylight overdrafts for financially sound depository institutions, including U.S. branches and agencies of foreign banking organizations, and (2) provide a streamlined approval process for other depository…
Continue Reading Federal Reserve Eases Daylight Overdraft Limits

President Trump signed a $484 billion stimulus bill into law today as part of the U.S. government’s ongoing efforts to contain the economic damage from the COVID-19.  The bill passed the House of Representatives and the Senate earlier this week with broad bipartisan support.

The measure is designed to supplement…
Continue Reading SBA Paycheck Protection Program to Receive Additional Funding

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

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 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…
Continue Reading CFTC Issues COVID-19 Related Relief for Futures and Swap Market Participants

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…
Continue Reading Visual Memo: CFTC Proposes Amendments to Cross-Border Rules

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…
Continue Reading Volcker 2.1: Agencies Propose Revisions to Covered Fund Provisions

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…
Continue Reading Encouraging Innovation: Brokered Deposits—What Fintechs Need to Know to Partner with Banks under the FDIC’s Proposed Regulations

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…
Continue Reading Client Memorandum: FSOC Shift to an Activities-Based Approach Signals an Emphasis on the Risks to Financial Stability from Digital Transformation

Building upon its BitLicense regime instituted in 2015, the New York State Department of Financial Services (NYDFS) has proposed two mechanisms by which entities that hold BitLicenses or trust charters with virtual currency authority (VC Licensees) may list or provide other approved services in a…
Continue Reading NYDFS Proposes a Streamlined Approval Process for Services in New Virtual Currencies