Our client alert discusses the SEC Division of Examinations list of priorities for 2023, which provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months.
Our client alert discusses the SEC Division of Examinations list of priorities for 2023, which provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months.
Our recent client alert covers the recent recordkeeping fines from the SEC and CFTC.
Our recent client alert discusses the CFTC’s longstanding practice of settling enforcement cases without seeking admissions of wrongdoing (so-called “no-admit/no-deny” settlements). CFTC Commissioner Romero suggests application of a “HEAT” test (Heightened Enforcement Accountability and Transparency), which would encourage CFTC staff to push for admissions of wrongdoing in actions with one or more bad…
Our recent client alert discusses the SEC complaint against three individuals alleging insider trading of digital assets via a scheme to trade ahead of multiple announcements regarding crypto assets being made available on a United States-based digital asset exchange at which one individual was a former product manager.
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.
On March 15, 2021, ISDA published the ISDA 2021 Security-Based Swaps (SBS) Top-Up Protocol (the SBS Top-Up Protocol). The SBS Top-Up Protocol enables SBS dealers (SBSDs) and other market participants to comply with certain SBS rules implemented by the SEC under Title VII of the Dodd–Frank Wall Street Reform and…
On March 17, 2021, Acting CFTC Chairman Rostin Behnam announced that the derivatives regulator had established a new interdivisional group called the Climate Risk Unit or the “CRU” to focus on the derivatives markets’ role in addressing climate-related risk and transitioning to a low-carbon/net-zero economy. The CRU (sounds like an…
On October 22, the SEC and CFTC held their first-ever joint open meeting to vote on a final rule. Never before in the 45-year history of the CFTC has the CFTC formally voted together with the SEC to adopt a joint rule. The joint final rule adopted by the CFTC and SEC…
On July 23, the CFTC adopted a final rule (Final Rule) under the Commodity Exchange Act (CEA) – CFTC Reg. § 23.23 – that (i) addresses the cross-border application of registration thresholds and certain “entity level” and “transaction level” requirements applicable to swap dealers (SDs) and major swap participants (MSPs), and (ii)…