Mr. Senackerib is an associate in Davis Polk's Financial Institutions Group. [Full Bio]

The Securities and Exchange Commission acted on the first of its proposals to substantially revamp the regulations concerning equity market data by issuing an order directing the national securities exchanges and the Financial Industry Regulatory Authority to propose a new National Market System equity market data plan. The new plan,
Continue Reading SEC Issues Order Requiring Changes to NMS Plan Governance

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.

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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

On December 10, 2019, the CFTC reopened the comment period for the proposed capital requirements for swap dealers (SDs) and major swap participants (MSPs) that are not subject to the capital rules of a prudential regulator (together, Covered Swap Entities).  These rules are the last
Continue Reading The Last Piece of the Puzzle: CFTC Reopens Comment Period for Capital Requirements and Proposes Amendments to Inter-Affiliate Swap Clearing Exemption

The CFTC’s Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued an advisory on December 4, 2019 to provide further guidance regarding the preparation and submission of chief compliance officer (“CCO”) annual compliance reports (“CCO Annual Reports”) for swap dealers (“SDs”), futures
Continue Reading CFTC Staff Issues Guidance Regarding Annual Chief Compliance Officer Reports

In a long-awaited milestone, the SEC has proposed an update of Guide 3, the industry guide for banking organizations.  The proposal eliminates a number of the current requirements under Guide 3 and streamlines many of those that remain.  The three “new” credit quality ratios in the proposal are, in practice,
Continue Reading Better Late Than Never: SEC Proposes Guide 3 Update

The Financial Standards Accounting Board (FASB) voted on Wednesday to propose delaying the implementation date of the Current Expected Credit Losses accounting standard (CECL) until 2023, for all companies other than larger SEC filers.  The proposal would reduce the number of implementation dates from three to
Continue Reading CECL Delayed for Small and Private Companies, But 2020 Implementation is Likely Here to Stay