Search Results: ATSs

SEC Publishes Spring Rulemaking Agenda: Torrid Pace Continues; Crypto Framework Noticeably Absent

Our recent client alert discusses the SEC’s “Reg Flex” agenda for rulemaking, which provides a glimpse into how the agency will prioritize its resources over the coming six months from a policy and rulemaking standpoint.

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SEC Examinations Division Publishes 2022 Priorities

The SEC Division of Examinations recently published its list of priorities for 2022.  While it was a bit late compared to a typical year, the priorities letter provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months. Significant focus areas…

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Ding, Dong! The Dealer/Trader Distinction is Dead. HFTs and DEX AMMs Should Take Notice

The SEC recently proposed rules that would greatly expand the Exchange Act definition of “dealer” and essentially kill the existing dealer/trader distinction long-recognized by the SEC.  The likely outcome is that most proprietary trading firms will need to register with the SEC as dealers and become members of FINRA or…

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SEC Proposes Rules that Could Regulate DeFi, Extend to Aspects of Centralized Crypto Exchanges

Here is a link to our client alert addressing the SEC’s proposed change to the “exchange” definition, including introduction of the new term “communication protocol system.” There were zero references to crypto, blockchain, DeFi, or distributed ledger technology in the 654-page proposal. Nevertheless, the proposal makes clear that it applies…

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tZERO ATS Settlement with SEC: Square Peg/Round Hole or Simple Failure to Follow Existing Rules?

On January 10, 2022, tZERO’s ATS settled a matter with the SEC in which it agreed to an $800,000 fine.  Given the size of the penalty and substantial attention on the SEC’s approach to regulating digital asset securities, readers may have thought that this would present a blockbuster set of…

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Is the SEC Still Considering Fixes to the Bond Markets?

The SEC has made a concerted effort in recent years to look more closely at the fixed income markets.  But under the new leadership of Chairman Gary Gensler, that spotlight seemed to have dimmed—or so some thought. For example, FIMSAC—the Fixed Income Market Structure Advisory Committee—which the SEC convened in…

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