Guidelines on covered fund seeding extensions from the Federal Reserve yesterday, following on the heels of last Friday’s guidance for foreign excluded funds, is a hopeful sign that the freeze on Volcker Rule guidance is finally thawing.  Perhaps these green shoots signal that broader, common sense relief is coming.  Yesterday’s … Read More

Ever since the final Volcker Rule regulations were made public in December 2013, foreign banks and their regulators have expressed concern about the extraterritorial reach of the Volcker Rule to certain foreign funds that have a foreign bank as sponsor or investor.  This policy issue has, as is often the … Read More

Jay Clayton’s first public speech on Wednesday as Chairman of the SEC foretold few, if any, sweeping regulatory changes at the Commission. His remarks, delivered to the Economic Club of New York, outlined eight principles that will guide his approach to regulation, which included support for the agency’s historic … Read More

There has been a slow start to financial regulatory reform under the Trump Administration, but the conversation is now changing in ways that are serious and thoughtful. This note highlights the key themes that we believe are important for mid-sized and regional banks in light of recent personnel announcements, … Read More

On December 22, 2016, the Federal Reserve released a staff paper on the implementation of the Volcker Rule and its impact on bond market liquidity, particularly in times of market stress. The paper studies the liquidity of downgraded corporate bonds before and after the implementation of the Volcker Rule and … Read More

An important, but sometimes misunderstood, SEC procedural requirement is the SEC’s quorum rule, which establishes the minimum number of Commissioners required for a Commission rulemaking.

Currently, only three of the five SEC Commissioner seats are filled. President Obama’s nominees for the two remaining slots, Hester Peirce and Lisa Fairfax, … Read More

President-Elect Trump’s transition website promises to “dismantle the Dodd-Frank Act and replace it with new policies to encourage economic growth and job creation.”  To help our clients keep up with the reorientation of the financial regulatory framework, Davis Polk is launching a new blog,

Our most recent entry … Read More

This blog post sets out how rollback of the Dodd-Frank Act or its implementing regulations might work. President Elect Trump’s administration and the new Republican majority in Congress could amend the relevant statutes or amend, repeal or block current regulations. Most of the methods are neither simple nor quick. Repealing … Read More