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On October 11, 2018, the SEC reopened the comment period and requested additional comments for previously proposed rules relating to capital, margin, and segregation requirements for security-based swap dealers (“SBSDs”), major security-based swap participants (“MSBSPs,” and together with SBSDs, “SBS Entities”) and, in some…
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As we head into the mid-term election season, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, confirmations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals; the later slides provide a deeper…
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Financial services regulatory reform in 2018 continues to evolve.  As we leave summer behind, here is the Fall Focus edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and will…
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After a several month lull that led some to question the SEC’s focus on crypto enforcement, this week saw a spate of enforcement activity involving crypto assets: several SEC enforcement actions, an SEC trading suspension order, the first FINRA cryptocurrency enforcement action, and a preliminary court decision consistent with the…
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Last week, the CFTC’s Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued time limited no-action relief to a regional commercial bank holding company and its insured depository institution (“IDI”) subsidiaries from having to count certain loan-related swaps toward its swap dealer de minimis threshold.  Currently,…
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The Center for Financial Stability is providing a freely accessible Financial Timeline, curated by Senior Fellow Yubo Wang.  The timeline, created in 2010 and actively maintained, charts more than 1,100 developments across the markets, institutions, the Federal Reserve, Treasury and other sources, from 2007 to the present.  This resource, which…
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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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As we head into the July 4th holiday and the heart of summer approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals;…
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