Mr. Means is an associate in Davis Polk’s Financial Institutions Group and the trading and markets practice. [Full Bio]

Responding to a 2016 request by the SEC (in consultation with the Treasury Department), FINRA recently reviewed the extent to which various FINRA rules apply to U.S. Treasury securities.  Following up on that analysis, on February 6, 2018, FINRA issued Regulatory Notice 18-05, requesting comment on whether it should … Read More

In the run up to the August recess, the Senate confirmed 76 of President Trump’s nominees last week, including a handful of senior personnel at various financial regulatory agencies. As we continue to track personnel changes at these agencies, we have updated our brief deck summarizing the leadership and staffing … Read More

The CFTC staff has once again extended its no-action relief from the “arrange, negotiate or execute” provisions of CFTC Advisory 13-69, the controversial 2013 advisory that applies transaction-level swap requirements based on the involvement of U.S.-located personnel.  Today’s relief differs from previous relief in that it does not have … Read More

The CFTC’s swap reporting rules, which were among the first swap rules finalized after Dodd-Frank, have also been among the most technically difficult for the industry to implement.  Regulatory and market participants agree that these technical difficulties have resulted in poor quality and inconsistent swap data, impeding the goal of … Read More

As the second quarter of 2017 comes to a close, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations and resignations and expiring terms. The first slide summarizes the state of play for the principals and the later slides provide … Read More