The CFTC unanimously approved Final Rule amendments on August 21, 2018 to the regulations governing chief compliance officer (“CCO”) duties and annual compliance reporting requirements for FCMs, swap dealers and MSPs (“Registrants”). These amendments are the first substantive rule amendments to be adopted under Chairman Giancarlo’s
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Our public memorandum here describes the notice of proposed rulemaking published by the CFTC on June 12, 2018 that would make permanent the $8 billion temporary swap dealer de minimis registration threshold currently in effect and would make other changes to the de minimis exception.

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Financial services regulatory reform in 2018 continues to evolve.  For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,
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Our visual memorandum here describes the proposed amendments to the Volcker Rule regulations issued by the Federal Reserve, FDIC, OCC, SEC and CFTC, as well as key requests for comment about possible additional amendments. To make the analysis more user-friendly, the memorandum incorporates elements of Davis Polk’s flowcharts on the
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Our visual memorandum here describes the key changes the Bipartisan Banking Act makes to the regulation of banking organizations. It is color coded for those who want to look only at the changes that affect their own organization.

The House is expected to pass the Economic Growth, Regulatory Relief and
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Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions
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CFTC Chairman J. Christopher Giancarlo and CFTC Chief Economist Bruce Tuckman released a White Paper on April 26, 2018 that reflects the authors’ personal views on the need for swaps regulatory reforms in the United States in five key areas:

  1. swap execution on swap execution facilities (“SEFs”);
  2. trade


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Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions
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The Senate passed the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) on March 14 by a filibuster-proof vote of 67 – 31.  The Senate bill still must pass the House, where Rep. Jeb Hensarling (R-TX) and other representatives have said they plan to propose a series of amendments
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