In the first major trading and markets initiative under SEC Chairman Jay Clayton, on March 14, 2018, the SEC proposed to establish a transaction fee pilot program to study the effects of maker-taker fee structures. A pilot study was initially recommended by the SEC’s Equity Market Structure Advisory Committee in
Continue Reading SEC Proposes Equity Market Study: Beginning of the End for the Maker-Taker Model?

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
Continue Reading Federal Reserve May Simplify the TLAC Rule

Many have commented on the suit filed last week challenging the CFPB’s arbitration rule, but few have considered what impact, if any, the suit could have on the fast-approaching compliance date of March 19, 2018.

As a reminder, the Chamber of Commerce and other trade associations filed a long-anticipated suit
Continue Reading Thoughts on Suit to Vacate CFPB Arbitration Rule

Regulatory Considerations for Integrating a Brokerage Firm into a Corporate Group

The recent Davis Polk and Oliver Wyman webcast discussion on the regulatory issues faced when integrating a broker-dealer, is now available On Demand for your convenience.

The webcast reviews our memoon common regulation-driven integration considerations.

View the Webcast
Continue Reading Webcast: So, Now You Own a Broker-Dealer!

Since the CFPB issued its Arbitration Rule in July, most commentators have focused on ways the rule may be blocked from going into effect. Chief among these is the possibility that Congress will vote to overturn the rule under the Congressional Review Act, and the House did promptly vote in
Continue Reading What Happens if the CFPB Arbitration Rule Isn’t Overturned? – Ten Practical Tips to Think About Now

President Trump issued a Presidential Memorandum last Friday, April 21, which directed the Treasury Secretary to conduct a review of the Orderly Liquidation Authority (OLA). OLA was established by Title II of the Dodd-Frank Act. Its potential repeal, with or without a new Chapter 14 (or subchapter V of Chapter
Continue Reading The Presidential Memorandum on the Orderly Liquidation Authority – Another Look