In a move that took some by surprise, SEC Chairman Jay Clayton on Tuesday rejected requests from the SROs to delay the implementation of the Consolidated Audit Trail (“CAT”), despite the SROs’ cybersecurity concerns and indications that the CAT is not yet operationally ready. Thus, the first phase of CAT … Read More
Ms. King is an associate in Davis Polk's Financial Institutions Group and the trading and markets practice. [Full Bio]
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. This request follows on the heels of a recommendation by the U.S. Treasury, … Read More
In the wake of a highly-publicized cybersecurity breach involving the SEC’s EDGAR system, SEC Chairman Jay Clayton has been in the hot seat at recent congressional hearings, fielding pointed questions as to whether the SEC should delay implementation of the Consolidated Audit Trail (“CAT”). The SEC has not announced a … Read More
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
In the August 25th episode of the CFTC podcast, CFTC Talks, the new Director of the CFTC’s Enforcement Division, James McDonald, discussed his priorities for the Division (transcript here), including providing incentives for entities to self-report non-compliance issues to the CFTC.
McDonald stressed that as part of … Read More
On December 22, 2016, the Federal Reserve released a staff paper on the implementation of the Volcker Rule and its impact on bond market liquidity, particularly in times of market stress. The paper studies the liquidity of downgraded corporate bonds before and after the implementation of the Volcker Rule and … Read More