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OVERVIEW

NEWS

PUBLICATIONS & PRESENTATIONS

Publications
  • 06.30.2016
    SEC Charges Private Fund Administrator with Gatekeeping Failures
    Updates
    The SEC announced two administrative settlements in June, with a fund administrator that provided accounting and fund administration services to several private funds based on its alleged failure to heed red flags and correct faulty accounting by two private fund managers.

    This update was republished in the Journal of Investment Compliance May 2017 issue, " SEC Charges Private Fund Administrator With Gatekeeping Failures ."
  • 03.07.2016
    Preparing for the SEC’s Increased Pursuit of Compliance Officers
    Updates
    The SEC’s recent aggressive enforcement posture against chief compliance officers has raised many concerns, including whether the SEC’s actions are actually chilling robust compliance efforts.

    This update was featured in Today's General Counsel on 03.17.2016 as "Is SEC Monday Morning Quarterbacking, By Targeting Compliance Officers?"
  • 02.19.2016
    California Supreme Court Holds That Borrowers May Bring Wrongful Foreclosure Actions Challenging Deed Of Trust Assignments
    Updates
    On February 18, 2016, the California Supreme Court held that borrowers may bring wrongful foreclosure claims based on challenges to an assignment of the note and deed of trust to a securitized trust.
  • 02.13.2015
    Financial Services Bulletin: Action at the SEC - 02.13.2015
    Updates
    On Thursday, December 18, 2014, the Securities and Exchange Commission (the “SEC”) proposed rule amendments to implement Title V and Title VI of the Jumpstart Our Business Startups Act (the “JOBS Act”).
  • 12.12.2014
    Financial Services Bulletin: Action at Federal Agencies - 12.12.2014
    Updates
    On Wednesday, November 5, 2014, the Federal Reserve Board (the "Board") issued a final rule that establishes a financial sector concentration limit pursuant to Section 622 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 10.28.2014
    Financial Services Bulletin: Action at Federal Agencies - 10.28.2014
    Updates
    On Friday, October 17, 2014, the Federal Reserve Board (the "Board") issued a final rule modifying the regulations for capital planning and stress testing and released instructions for the 2015 capital planning cycle.
  • 10.06.2014
    Financial Services Bulletin: Action at Federal Agencies - 10.06.2014
    Updates
    On Friday, August 22, 2014, the Federal Reserve Board (the "Board") requested comments on its proposal to repeal its Regulation AA, which deals with unfair or deceptive acts or practices.
  • 08.21.2014
    Financial Services Bulletin: Action at the SEC - 08.21.2014
    Updates
    On Wednesday, July 23, 2014, the Securities and Exchange Commission (the “SEC”) adopted amendments to the rules governing money market mutual funds (or “money market funds”) pursuant to Rule 2a-7 under the Investment Company Act of 1940 (“Investment Company Act” or “Act”).
  • 07.03.2014
    Financial Services Bulletin: Action at the SEC - 07.03.2014
    Updates
    On Wednesday, June 25, 2014, the Securities and Exchange Commission (the "SEC") issued new rules and guidance regarding cross-border security-based swap activities for market participants. The SEC issued the new rules as part of a series of rules proposed in May 2013 to address the application to cross-border activities of security-based swap regulatory requirements under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
  • 04.23.2014
    Financial Services Bulletin: Action at Federal Agencies - 04.23.2014
    Updates
    On Tuesday, April 8, 2014, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the "Agencies") jointly issued a final rule that establishes an enhanced supplementary leverage ratio for the largest United States banking organizations.
  • 04.03.2014
    Financial Services Bulletin: Action at Federal Agencies - 04.03.2014
    Updates
    On Monday, March 24, 2014, the Office of the Comptroller of Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, the Federal Housing Finance Agency, and the National Credit Union Administration issued a proposed rule that would implement minimum requirements for state registration and supervision of appraisal management companies (“AMCs”).
  • 03.20.2014
    Financial Services Bulletin: Action at Federal Agencies - 03.20.2014
    Updates
    On Wednesday, March 5, 2014, the Board of Governors of the Federal Reserve System (the "Board"), the Federal Deposit Insurance Corporation (the "FDIC") and the Office of the Comptroller of Currency (the "OCC") issued final guidance regarding stress testing for financial companies with total consolidated assets between $10 billion and $50 billion ("Medium-Sized Firms").
  • 02.27.2014
    Financial Services Bulletin: Action at the SEC and FRB - 02.27.2014
    Updates
    On Thursday, February 6, 2014, the Securities and Exchange Commission (the “SEC”) released guidance regarding who qualifies as a “knowledgeable employee” in rule 3c-5 under the Investment Company Act of 1940 (“Investment Company Act”).
  • 02.05.2014
    Financial Services Bulletin: Action at the Consumer Financial Protection Bureau
    Updates
    On Thursday, January 23, 2014, the Consumer Financial Protection Bureau (the "CFPB") proposed a rule to allow oversight of larger nonbank international money transfer providers for compliance with the CFPB's October 2013 "Remittance Rule," which is designed to protect consumers sending money abroad.
  • 01.21.2014
    Financial Services Bulletin: Action at Federal Agencies - 01.21.2014
    Updates
    On Thursday, January 14, 2013, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Commodity Futures Trading Commission, and the Securities and Exchange Commission approved an interim final rule to permit banking entities to retain interests in certain collateralized debt obligations backed primarily by trust preferred securities from the investment prohibitions of Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, known as the Volcker rule.
  • 01.09.2014
    Financial Services Bulletin: Action at the Federal Reserve Board
    Updates
    On Monday, December 23, 2013, the Federal Reserve Board proposed amendments to Regulation A (Extensions of Credit by Federal Reserve Banks) to implement Sections 1101 and 1103 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"), which amended the Federal Reserve Board's emergency lending authority in Section 13(3) of the Federal Reserve Act.
  • 12.20.2013
    Financial Services Bulletin: Action at Federal Agencies - 12.20.2013
    Updates
    On Thursday, December 12, 2013, the Federal Reserve Board, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the National Credit Union Administration, and the Office of the Comptroller of the Currency issued a final rule that creates exemptions from certain appraisal requirements for a subset of higher-priced mortgage loans.
  • 12.12.2013
    Financial Services Bulletin: Action at Federal Agencies - 12.12.2013
    Updates
    On Wednesday, December 5, 2013, the Federal Reserve Board (the "Federal Reserve") adopted final rules that amend Regulation HH pursuant to Section 806 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 12.09.2013
    Financial Services Bulletin: Action at the CFPB
    Updates
    On Tuesday, December 3, 2013, the Consumer Financial Protection Bureau (the "CFPB") issued a final rule pursuant to the CFPB’s authority under Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
  • 11.25.2013
    Financial Services Bulletin: Action at the CFTC and CFPB - 11.25.2013
    Updates
    On Friday, November 8, 2013, the Commodity Futures Trading Commission (the "CFTC") proposed amending its regulations to require that all persons registered with the CFTC as introducing brokers, commodity pool operators, and commodity trading advisors must become and remain members of at least one registered futures association.
  • 11.07.2013
    Financial Services Bulletin: Action at the CFTC - 11.07.2013
    Updates
    On Tuesday, November 5, 2013, the Commodity Futures Trading Commission (the “CFTC”) proposed two sets of position limit related rules pursuant to Section 4a of the Commodity Exchange Act (the “CEA”), as amended by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).
  • 10.31.2013
    Financial Services Bulletin: Action at Federal Agencies - 10.31.2013
    Updates
    On Wednesday, October 23, 2013, the Securities and Exchange Commission (the "SEC") voted unanimously to propose rules to permit companies to offer and sell securities through "crowdfunding," under Title III of the Jumpstart Our Business Startups Act (the "JOBS Act").
  • 2010 - 2013
  • 10.04.2013
    Financial Services Bulletin: Action at The SEC and Fed - 10.04.2013
    Updates
    On Wednesday, September 18, 2013, the Securities and Exchange Commission (the “SEC”) voted 3-2 to propose a new rule that would require public companies to disclose the ratio of the compensation of its chief executive officer (“CEO”) to the median compensation of its employees.
  • 08.29.2013
    Financial Services Bulletin: Action at Federal Agencies - 08.29.2013
    Updates
    On Tuesday, August 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) issued a final rule to exempt swaps entered into by qualified cooperatives from the clearing requirement under Section 2(h)(1)(A) of the Commodity Exchange Act (the “CEA”) and part 50 of the CFTC’s regulations, subject to certain conditions.
  • 08.08.2013
    Financial Services Bulletin: Action at the Fed, FDIC, and OCC
    Updates
    On Tuesday, July 30, 2013, the Board of Governors of the Federal Reserve System (the “Fed”), the Federal Deposit Insurance Corporation (the “FDIC”), and the Office of the Comptroller of the Currency (the “OCC”) proposed guidance describing supervisory expectations for stress tests conducted by financial companies with total consolidated assets between $10 billion and $50 billion.
  • 07.25.2013
    Financial Services Bulletin: Action at the FRB, CFPB and OCC
    Updates
    On Wednesday, July 10, 2013, the Board of Governors of the Federal Reserve System (the “Fed”), Bureau of Consumer Financial Protection, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller of the Currency issued a proposed rule that would create exemptions from certain appraisal requirements for a subset of higher-priced mortgage loans.
  • 07.11.2013
    Financial Services Bulletin: Action at the SEC, FRB, FDIC, and OCC - 07.11.2013
    Updates
    On Wednesday, July 10, 2013, the Securities and Exchange Commission (the “SEC”) adopted amendments to Rule 506 of Regulation D and Rule 144A under the Securities Act of 1933 to implement Section 201(a) of the Jumpstart Our Business Startups Act (the “JOBS Act”).
  • 06.27.2013
    Financial Services Bulletin: Action at the OCC and CFPB
    Updates
    On Wednesday, June 19, 2013, the Office of the Comptroller of the Currency (the “OCC”) finalized its lending limits interim final rule, with revisions. The interim final rule consolidated the lending limits rules applicable to national banks and savings associations, removed the separate OCC regulation governing lending limits for savings associations, and implemented Section 610 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 06.14.2013
    Financial Services Bulletin: Action at the SEC, Fed, and FDIC - 06.14.2013
    Updates
    On Wednesday, June 5, 2013, the Securities and Exchange Commission (the “SEC”) voted unanimously to propose rules that would reform the way that certain money market funds operate in order to make them less susceptible to runs that could harm investors.  The SEC’s proposal includes two principal alternative reforms that could be adopted alone or in combination.  One alternative would require a floating net asset value per share (NAV) for prime institutional money market funds.  The other alternative would allow the use of liquidity fees and redemption gates in times of stress.  The proposal also includes additional diversification and disclosure measures that would apply under either alternative.
  • 06.06.2013
    Financial Services Bulletin: Action at the CFPB, SEC, and CFTC
    Updates
    On Wednesday, May 29, 2013, the Consumer Financial Protection Bureau (the “CFPB”) issued amendments to Regulation Z, which implements the Truth in Lending Act (“TILA”).  TILA Section 129C, as added by Sections 1411, 1412, and 1414 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), generally requires creditors to make a reasonable, good faith determination of a consumer’s ability to repay a mortgage loan and creates a presumption of compliance with these ability-to-repay requirements for certain loans designated as “qualified mortgages.
  • 05.22.2013
    Financial Services Bulletin: Action at the CFPB
    Updates
    On Thursday, May 16, 2013, the Consumer Financial Protection Bureau (the "CFPB") adopted clarifying and technical amendments to its Escrow Requirements Under the Truth in Lending Act final rule issued on January 10, 2013.
  • 05.09.2013
    Financial Services Bulletin: Action at the SEC - 05.09.2013
    Updates
    On Wednesday, May 1, 2013, the Securities and Exchange Commission (the "SEC") proposed rules and interpretive guidance for parties to cross-border security-based swap transactions.
  • 05.01.2013
    Financial Services Bulletin: Action at the CFPB, OCC, FDIC, and Fed
    Updates
    On Thursday, April 25, 2013, the Office of the Comptroller of the Currency (the "OCC") and the Federal Deposit Insurance Corporation (the "FDIC") proposed guidance and the Board of Governors of the Federal Reserve System (the "Fed") issued a statement related to deposit advance products.
  • 04.18.2013
    Financial Services Bulletin: Action at the CFTC, SEC, CFPB, Fed, and FDIC - 04.18.2013
    Updates
    On Wednesday, April 10, 2013, the Commodity Futures Trading Commission (the "CFTC") and the Securities and Exchange Commission (the "SEC") jointly issued final rules and guidelines that will require certain regulated entities to establish programs to address risks of identity theft.
  • 04.11.2013
    Financial Services Bulletin: Action at the CFTC, SEC, and Fed - 04.11.2013
    Updates
    On Thursday, March 28, 2013, the Commodity Futures Trading Commission (the "CFTC") approved a final order that exempts certain non-financial energy derivative transactions between and amongst government-owned electric utilities and cooperatively-owned electric utilities from most of the requirements of the Commodity Exchange Act (the "CEA") and the CFTC's regulations, subject to certain anti-fraud, anti-manipulation, and record inspection conditions.
  • 03.20.2013
    Financial Services Bulletin: CFPB Proposes Student Loan Rule
    Updates
    On Thursday, March 14, 2013, the Consumer Financial Protection Bureau (the "CFPB") proposed, pursuant to Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act, a rule that would identify a market for student loan servicing, and define certain nonbank student loan servicers as "larger participants," thereby allowing the CFPB to oversee their activity for compliance with federal consumer financial laws.
  • 03.19.2013
    D.C. Circuit Rules That CFTC – Not FERC – Has Authority to Regulate Futures Trades
    Updates
    On March 15, 2013, the U.S. Court of Appeals for the District of Columbia Circuit held that the Commodity Futures Trading Commission (CFTC) has exclusive jurisdiction over natural gas futures contracts and that the Federal Energy Regulatory Commission (FERC) had exceeded its authority when it fined Brian Hunter, a trader for hedge fund Amaranth, $30 million for allegedly manipulating natural gas futures contracts.
  • 03.14.2013
    Financial Services Bulletin: Action at the CFTC and SEC - 03.14.2013
    Updates
    On Wednesday, March 6, 2013, the Commodity Futures Trading Commission (the "CFTC") approved the request from the Chicago Mercantile Exchange Inc. (the "CME") for the CME to adopt new Chapter 10 and new Rule 1001 in the CME’s rulebook.
  • 03.07.2013
    Financial Services Bulletin: Action at the SEC - 03.07.2013
    Updates
    On Friday, March 1, 2013, the Securities and Exchange Commission (the "SEC") issued a release requesting data and other information, in particular quantitative data and economic analysis, relating to the benefits and costs that could result from various alternative approaches regarding the standards of conduct and other obligations of broker-dealers and investment advisers.
  • 02.28.2013
    Financial Services Bulletin: New Rules Proposed by the Fed
    Updates
    On Thursday, February 26, 2013, the Federal Reserve Board (the "Fed") introduced a proposed rule pursuant to Title VIII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 01.31.2013
    Financial Services Bulletin: CFPB Issue New Final Rules
    Updates
    On Thursday, January 10, 2013, Consumer Financial Protection Bureau (the "CFPB") issued a final rule that amends Regulation Z to implement certain amendments to the Truth in Lending Act ("TILA") made by Sections 1461 and 1462 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 01.25.2013
    Financial Services Bulletin: Agencies Issue New Mortgage Rules
    Updates
    On Friday, January 18, 2013, the Board of Governors of the Federal Reserve System (the “Fed”), the Consumer Financial Protection Bureau (the "CFPB"), the Federal Deposit Insurance Corporation (the “FDIC”), the Federal Housing Finance Agency (the “FHFA”), the National Credit Union Administration (the “NCUA”), and the Office of the Comptroller of the Currency (the “OCC”) issued a final rule that establishes new appraisal requirements for "higher-priced mortgage loans."
  • 01.17.2013
    Financial Services Bulletin: Action at the CFPB
    Updates
    On Thursday, January 10, 2013, the Consumer Financial Protection Bureau ("CFPB") issued a final rule amending Regulation Z pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). Regulation Z, which implements the Truth in Lending Act, prohibits a creditor from making a higher-priced mortgage loan without regard to the consumer’s ability to repay the loan.
  • 01.10.2013
    Financial Services Bulletin: Action at the OCC and CFTC
    Updates
    On Thursday, January 3, 2013, the Office of the Comptroller of the Currency (the "OCC") provided guidance regarding requests for a transition period pursuant to Section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 01.03.2013
    Financial Services Bulletin: Action at the SEC - 01.03.2013
    Updates
    On Friday, December 21, 2012, the Securities and Exchange Commission (the "SEC") adopted amendments to Exchange Act Rule 17Ad-17 to implement the requirements of Section 929W of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
  • 12.20.2012
    Financial Services Bulletin: Action at the CFTC and Fed - 12.20.2012
    Updates
    On Thursday, December 13, 2012, the Commodity Futures Trading Commission ("CFTC") announced that it is adopting regulations to establish a clearing requirement under Section 2(h)(1)(A) of the Commodity Exchange Act, enacted under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 12.06.2012
    Financial Services Bulletin: Action at the CFTC - 12.06.2012
    Updates
    On Wednesday, November 28, 2012, the Commodity Futures Trading Commission (the "CFTC") requested public comment on a request from the Chicago Mercantile Exchange Inc. ("CME") for approval of Rule 1001 submitted pursuant to section 40.5 of the CFTC’s regulations.
  • 11.29.2012
    Financial Services Bulletin: Action at Federal Agencies - 11.29.2012
    Updates
    On Friday, November 9, 2012, the Board of Governors of the Federal Reserve System (the "Fed"), the Federal Deposit Insurance Corporation (the "FDIC"), and the Office of the Comptroller of the Currency (the "OCC") issued a joint press release concerning the three notices of proposed rulemaking issued in June that would revise and replace the current regulatory capital rules.
  • 11.01.2012
    Financial Services Bulletin: Action at the CFTC - 11.01.2012
    Updates
    On Tuesday, October 23, 2012, the Commodity Futures Trading Commission (the "CFTC") proposed new regulations and amendments to existing regulations pursuant to Sections 4d(a)(2) and Section 4d(f) of the Commodity Exchange Act (the "CEA"), as amended by Section 724(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 10.25.2012
    Financial Services Bulletin: Action at the SEC, DC Circuit Court and the CFTC - 10.25.2012
    Updates
    On Wednesday, October 17, 2012, the Securities and Exchange Commission (the SEC) voted unanimously to propose capital, margin, and segregation requirements for security-based swap dealers and major security-based swap participants.
  • 10.18.2012
    Financial Services Bulletin: Action at the CFTC - 10.18.2012
    Updates
    On Tuesday, October 16, 2012, the Commodity Futures Trading Commission approved a final rule that amends certain current regulations in order to implement aspects of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).
  • 10.11.2012
    Financial Services Bulletin: Final Stress Test Rules
    Updates
    On Tuesday, October 9, 2012, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the "Regulators") each published final rules with stress testing requirements for certain covered institutions.
  • 10.08.2012
    Financial Services Bulletin: Updates on NYSE, NASDAQ, and CFTC Rules
    Updates
    On Tuesday, September 25, 2012, the New York Stock Exchange ("NYSE") and the NASDAQ Stock Marker ("Nasdaq") filed proposed amendments to their listing standards to reflect the requirements of Rule 10C-1 under the Securities Exchange Act of 1934 (the "Exchange Act").
  • 09.27.2012
    Financial Services Bulletin: Joint Fed, OCC and FDIC Release
    Updates
    On Monday, September 24, 2012, the Federal Reserve Board (the "Fed"), the Federal Deposit Insurance Corporation (the "FDIC"), and the Office of the Comptroller of the Currency (the "OCC") announced the availability of a regulatory capital estimation tool to help community banking organizations and other interested parties evaluate recently published regulatory capital proposals.
  • 09.12.2012
    Financial Services Bulletin: SEC and CFTC Action
    Updates
    On Wednesday, August 29, 2012, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 506 of Regulation D and Rule 144A under the Securities Act of 1933 pursuant to Section 201(a) of the Jumpstart Our Business Startups Act.
  • 08.29.2012
    Financial Services Bulletin: Action at Several Federal Agencies - 08.29.2012
    Updates
    On Tuesday, August 21, 2012, the Commodity Futures Trading Commission (the "CFTC") ' approved a proposed order that would exempt certain specified transactions of Regional Transmission Organizations ("RTOs") and Independent System Operators ("ISOs") from certain provisions of the Commodity Exchange Act (the "CEA"), as amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"), and CFTC regulations.
  • 08.22.2012
    Financial Services Bulletin: Action at the CFTC - 08.22.2012
    Updates
    On Thursday, August 16, 2012, the Commodity Futures Trading Commission (the "CFTC") issued a proposed rule to exempt swaps between certain affiliated entities within a corporate group from the clearing requirement of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 08.16.2012
    Financial Services Bulletin: Action At Federal Agencies - 08.16.2012
    Updates
    On Tuesday, August 7, 2012, the Commodity Futures Trading Commission (the "CFTC") proposed regulations to establish a clearing requirement under new Section 2(h)(1)(A) of the Commodity Exchange Act (the "CEA"), enacted under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 08.02.2012
    Financial Services Bulletin: Senate, CFTC, and Fed Action
    Updates
    On Monday, July 23, 2012, U.S. Senators Charles Grassley (R-IA) and Jack Reed (D-RI) introduced S.3416, the Stronger Enforcement of Civil Penalties Act of 2012.  S.3416 would increase to the statutory limits on the amounts that the Securities and Exchange Commission (the "SEC") may seek to penalize individuals and entities charged with securities law violations in administrative and civil actions.
  • 07.25.2012
    Financial Services Bulletin: Action at the FSOC and CFTC
    Updates
    On Wednesday, July 18, 2012, the Financial Stability Oversight Council (the "FSOC") voted unanimously to designate eight financial market utilities ("FMUs") as systemically important under Title VIII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").  This action is the first such designation made by the FSOC.
  • 07.19.2012
    Financial Services Bulletin: CFTC Takes Multiple Actions on Swap Regulation
    Updates
    On Tuesday, July 10, 2012, the Commodity Futures Trading Commission ("CFTC") voted to adopt a final rule and approve a proposed rule regarding exceptions to the swap clearing requirement established in Section 2(h)(1) of the Commodity Exchange Act (the "CEA"), as amended by Section 723 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 07.17.2012
    Financial Services Bulletin: SEC and CFTC Adopt Definitions for Key Derivative Terms
    Updates
    On Friday, July 6, 2012, the Securities and Exchange Commission (the "SEC"), and on Tuesday, July 10, 2012, the Commodity Futures Trading Commission (the "CFTC"), approved joint rules and interpretations for key definitions of certain derivative products. The rules and interpretations further define the terms “swap” and “security-based swap” and whether a particular instrument is a “swap” regulated by the CFTC or a “security-based swap” regulated by the SEC.
  • 07.05.2012
    Financial Services Bulletin: Action on Swap Regulation at the SEC and CFTC
    Updates

    The SEC Adopts Swap Clearing Agency Rules.

    On Thursday, June 28, 2012, the Securities and Exchange Commission (the "SEC") adopted rules that establish procedures for its review of certain clearing agency actions.  The rules are required by Title VIII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"), which calls for a regulatory framework for trading in over-the-counter derivatives, including swap agreements.  The rules detail how clearing agencies are to provide information to the SEC about security-based swaps that the clearing agencies plan to accept for clearing.  The information is intended to aid the SEC in determining whether such security-based swaps are required to be cleared.  The rules also require clearing agencies that are designated as "systemically important" to submit advance notice of changes to their rules, procedures, or operations if the changes could materially affect the nature or level of risk at those clearing agencies.

    Read the SEC press release rule (Insert: http://www.sec.gov/news/press/2012/2012-124.htm)

  • 06.27.2012
    Financial Services Bulletin: Action at the CFTC, OCC, and SEC - 06.27.2012
    Updates
    On Friday, June 15, 2012, the Commodity Futures Trading Commission (the "CFTC") proposed regulations pursuant to Title VII of the Dodd-Frank Act Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). The proposed regulations would clarify that each swap dealer ("SD"), major swap participant ("MSP"), and other CFTC registrant with whom an associated person ("AP") is associated is required to supervise the AP and is jointly and severally responsible for the activities of the AP with respect to customers common to it and another SD, MSP or another CFTC registrant.
  • 06.14.2012
    Financial Services Bulletin: Action at the CFPB, Fed, OCC, FDIC, and SEC
    Updates
    On Wednesday, June 6, 2012, the Consumer Financial Protection Bureau (the "CFPB") announced three final rules to implement provisions of Sections 1052, 1053, and 1042 of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act (the "Dodd-Frank Act") and one interim final rule to implement provisions of the Equal Access to Justice Act (the "EAJA").  The three final rules deal with the CFPB’s investigative and adjudicative processes and its interactions with state law enforcement authorities.  The interim final rule implements the EAJA provisions that certain prevailing parties in administrative proceedings can recover attorney fees and expenses.
  • 06.07.2012
    Financial Services Bulletin: Agencies Sign Supervisory Coordination MOU
    Updates
    On Monday, June 4, 2012, the Consumer Financial Protection Bureau (the "CFPB"), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency released a Memorandum of Understanding that clarifies how the agencies will coordinate their supervisory activities, consistent with the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 05.31.2012
  • 05.17.2012
    Financial Services Bulletin: Agency Stress Testing Releases and Further Delayed Swap Regulation
    Updates
    On Monday, May 14, 2012, the Federal Reserve Board (the "Fed"), the Office of the Comptroller of the Currency (the "OCC"), and the Federal Deposit Insurance Corporation (the "FDIC") issued final supervisory guidance regarding stress-testing practices at banking organizations with total consolidated assets of more than $10 billion. The guidance does not implement the stress testing requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") or in the Fed's capital plan rule that apply to certain companies, as those requirements have been or are being implemented through separate proposals by the respective agencies.
  • 05.03.2012
    Financial Services Bulletin: Action at the CFTC - 05.03.2012
    Updates
    On Friday, April 27, 2012, the Commodity Futures Trading Commission ("CFTC") issued a final rule to repeal and replace the CFTC's current regulations concerning commodity options.  The CFTC also issued an interim final rule (with a request for additional comment) that incorporates a trade option exemption into the final rules for certain commodity options.
  • 04.26.2012
    Financial Services Bulletin: New SEC Rule and Joint Federal Agency Release
    Updates
    On Wednesday, April 18, 2012, the Securities and Exchange Commission (the "SEC") unanimously adopted a new rule to define a series of terms related to the over-the-counter swaps market. The rules, adopted pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"), were written jointly with the Commodity Futures Trading Commission (the "CFTC").
  • 04.19.2012
    Financial Services Bulletin: CPSS and IOSCO Issue Principles for Financial Market Infrastructures Report
    Updates
    On Monday, April 16, 2012, the Committee on Payment and Settlement Systems ("CPSS") and the Technical Committee of the International Organization of Securities Commissions ("IOSCO") published the final report on the Principles for Financial Market Infrastructures. The report updates, harmonizes, and strengthens the risk management and related standards applicable to financial market infrastructures ("FMIs"), including systemically important payment systems, central securities depositories, securities settlement systems, central counterparties, and trade repositories.
  • 04.12.2012
    Financial Services Bulletin: JOBS Act and New Releases from the CFTC, Fed, FDIC, FSOC, OCC, and SEC
    Updates
    On Thursday, April 5, 2012, President Obama signed the Jumpstart Our Business Startups Act (the "JOBS Act") into law.  The JOBS Act's stated purpose is to spur job creation and economic growth by improving access to capital for emerging growth companies by making some of the most significant changes to the U.S. securities law landscape in over a generation.
  • 03.30.2012
    JOBS Act Heralds New Era for Startup and Emerging Growth Company Financing
    Updates
    As forecast, on March 27 the U.S. House passed the Senate's amended version of the Jumpstart Our Business Startups Act (the JOBS Act), clearing the way for President Obama to sign the bill into law, which he is expected to do in the coming days.
  • 03.28.2012
    Financial Services Bulletin: Action at the FDIC, CFTC, Fed, and OCC
    Updates
    On Tuesday, March 20, 2012, the Federal Deposit Insurance Company (the “FDIC”) published two Notices of Proposed Rulemaking.  The first would implement section 201(c)(16) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), which permits the FDIC as receiver for a failed “systemically important financial institution,” or “SIFI,” to enforce and prevent termination of the contracts of the institution's subsidiaries or affiliates.
  • 03.22.2012
    Financial Services Bulletin: White Paper on CFPB Regulation of Nonbanks and the CFTC Proposes Swap Grouping Rule
    Updates
    On Monday February 20, 2012, Perkins Coie LLP Partner George Fogg published a white paper addressing the authority of the Consumer Financial Protection Bureau (the “CFPB”) to regulate certain nonbanks.
  • 02.29.2012
    Financial Services Bulletin: CFTC and SEC Action
    Updates
    On Friday February 24, 2012, the Commodity Futures Trading Commission both adopted and proposed new regulations aimed at harmonizing the compliance obligations of investment companies required to register as Commodity Pool Operators ("CPOs") pursuant to the Commodities Exchange Act.  The newly adopted final rules both amend the existing CFTC part 4 regulations and add a new rule regarding CPOs and Commodity Trading Advisors ("CTAs").
  • 02.22.2012
    Financial Services Bulletin: New SEC and CFTC Rules
    Updates
    On Wednesday February 15, 2012, the Securities and Exchange Commission (the "SEC") announced tightened rules on investment advisory performance fees, raising the net worth requirement for investors who pay performance fees by excluding the value of the investor’s home from the net worth calculation.
  • 02.16.2012
    Financial Services Bulletin: CFTC Issues Volcker Rule Proposal
    Updates
    On Tuesday February 14, 2012, the Commodity Futures Trading Commission (the "CFTC") proposed regulations that would implement Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection, commonly known as the "Volker Rule."
  • 02.09.2012
    Financial Services Bulletin: New CFTC Regulations and Joint CFTC/SEC Report
    Updates
    On Tuesday January 31, 2012, the Commodity Futures Trading Commission (the "CFTC") and the Securities and Exchange Commission (the "SEC") delivered to Congress a report on international swap regulation, as required by Section 719(c) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 02.02.2012
    Financial Services Bulletin: GAO Releases Bank Study and FTC and CFPB Issue MOU
    Updates
    On Thursday, January 19, 2012, Government Accountability Office (the "GAO") released a study on the institutions exempt from the definition of "bank" under Section 2 of the Bank Holding Company Act.
  • 01.27.2012
    SEC Warns Investment Advisers About Social Media Use
    Updates
    Just as more professionals have started taking advantage of social media to develop and grow their business, the financial services industry is following suit.  However, given the highly regulated nature of this industry, financial services professionals must be aware of special regulatory considerations when utilizing social networking tools.
  • 01.25.2012
    Financial Services Bulletin: New CFTC Rules, Proposed OCC Rules, and Public Input for an SEC Study
    Updates
    On Wednesday, January 18, 2012, the Securities and Exchange Commission (the "SEC") published a request for public comment on financial literacy and investor disclosure issues that it is studying as part of a review mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). Section 917 of the Dodd-Frank Act directs the SEC to conduct a study of retail investors’ financial literacy and submit its findings to Congress by July 21, 2012.
  • 01.19.2012
    Financial Services Bulletin: CFPB Begins Non-Bank Supervision Program and New CFTC Rules on Swaps
    Updates
    On Thursday, January 5, 2012, the Consumer Financial Protection Bureau (the "CFPB") announced the launch of its non-bank supervision program under Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").  The CFPB already began its supervision of banks, thrifts, and credit unions with assets of over $10 billion on July 21, 2011.
  • 01.12.2012
    Financial Services Bulletin: New Rules on Real-Time Reporting of Swap Transaction Data
    Updates
    On Monday, January 9, 2012, the Commodity Futures Trading Commission adopted final rules to implement a framework for the real-time public reporting of swap transaction and pricing data for all swap transactions.
  • 01.03.2012
    Financial Services Bulletin: Volcker Rule Comment Period Extended and New Final Rules at the SEC, CFTC, and the Fed
    Updates
    On Wednesday, December 21, 2011, the Securities and Exchange Commission (the "SEC") adopted rules to implement Section 1503 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 12.22.2011
    Financial Services Bulletin: Two New Final Rules at the CFTC
    Updates
    On Wednesday, December 7, 2011, the Commodity Futures Trading Commission ("CFTC") amended its regulations regarding the investment of customer segregated funds subject to CFTC Regulation 1.25 and funds held in an account subject to CFTC Regulation 30.7.
  • 12.16.2011
    Financial Services Bulletin: Amended Proposed Rules and Other Releases
    Updates
    On Wednesday, December 7, 2011, the Commodity Futures Trading Commission ("CFTC") issued a Guidebook for Part 20 Reports providing additional guidance and detailed instructions for submitting large swaps trader reports to the Commission.
  • 12.07.2011
    Financial Services Bulletin: CFTC Issues Interpretation Concerning Dodd-Frank Anti-Fraud Authority
    Updates
    On Friday, December 2, 2011, the Commodity Futures Trading Commission ("CFTC") announced an interpretation that relates to anti-fraud authority provided in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 11.30.2011
    Financial Services Bulletin: OCC Proposes Removal of Credit Rating References
    Updates
    On Tuesday, November 29, 2011, the Office of the Comptroller of the Currency ("OCC") proposed a rule to remove references to credit ratings from various OCC regulations and related guidance to national banks and federal savings associations in meeting due diligence requirements in assessing credit risk for portfolio investments.
  • 11.23.2011
    Financial Services Bulletin: New Rules at the CFTC and Fed and a Multi-Agency Joint Statement on Federal Consumer Financial Laws
    Updates
    On Thursday, November 17, 2011, the Board of Governors of the Federal Reserve System (the "Federal Reserve"), the Consumer Financial Protection Bureau (the "CFPB"), the Federal Deposit Insurance Corporation (the "FDIC"), the National Credit Union Administration (the "NCUA"), and the Office of the Comptroller of the Currency (the "OCC") issued a joint statement that seeks to explains how the total assets of an insured bank, thrift or credit union will be measured for purposes of determining supervisory and enforcement responsibilities under the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act'').
  • 11.10.2011
    Reminder: Filing Deadline Is December 1 Under New SEC Large Trader Reporting Rules
    Updates
    The Securities and Exchange Commission (the "SEC") recently adopted Rule 13h-1 of the Securities Exchange Act of 1934 (the "Exchange Act") and related Form 13H, establishing new reporting and filing requirements for "large traders" of securities in U.S. markets.
  • 11.09.2011
    Financial Services Bulletin: The CFTC Adopts Rules on Derivatives Clearing Organization Activities
    Updates
    On Tuesday, November 8, 2011, the Commodity Futures Trading Commission (the "CFTC") adopted final regulations to implement certain provisions of Title VII and Title VIII of the Dodd-Frank Wall Street Reform and Consumer Protection Act governing derivatives clearing organization ("DCO") activities.
  • 11.03.2011
    Financial Services Bulletin: The SEC and CFTC Approve Joint Rule on Confidential Private Fund Risk Reporting
    Updates
    On Wednesday, October 26, 2011, and Monday, October 31, 2011, the Securities and Exchange Commission (the "SEC") and the Commodity Futures Trading Commission (the "CFTC") approved a new joint rule requiring certain advisers to hedge funds and other private funds to report information for use by the Financial Stability Oversight Council in monitoring risks to the U.S. financial system.
  • 10.27.2011
    Financial Services Bulletin: The CFTC Proposes Again Extending the Effective Date of Certain Dodd-Frank Provisions
    Updates
    On Tuesday, October 25, 2011, the Commodity Futures Trading Commission (the "CFTC") issued a notice of a proposed amendment to a July 14, 2011 final order (the "July 14th Order").  The July 14th Order grants temporary exemptive relief from certain provisions of the Commodity Exchange Act (the "CEA") that otherwise would have taken effect on July 16, 2011, the general effective date of title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 10.19.2011
    Financial Services Bulletin: The Fed and the FDIC Implement Annual Resolution Plan Regulation
    Updates
    On Monday, October 17, 2011, the Federal Reserve Board (the "Board") announced that the Board and the Federal Deposit Insurance Corporation (the "FDIC") adopted a final rule implementing the resolution plan requirement of Section 165(d)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  Section 165(d)(1) requires each non-bank financial company designated by the Financial Stability Oversight Council ("FSOC") for enhanced supervision by the Board and each bank holding company with assets of $50 billion or more to report periodically to the Board, the FDIC, and the FSOC the company's plan for rapid and orderly resolution in the event of material financial distress or failure.
  • 10.13.2011
    Financial Services Bulletin: New Proposed Rules as the OCC, Fed, FDIC, and SEC and FSOC Issues a Notice of Proposed Rulemaking and Proposed Interpretive Guidance
    Updates
    On Tuesday, October 11, 2011, the Office of the Comptroller of the Currency (the "OCC"), the Federal Reserve Board (the "Fed"), the Federal Deposit Insurance Corporation (the "FDIC"), and the Securities and Exchange Commission (the "SEC") jointly issued proposed regulation implementing the so-called "Volcker Rule" requirements of section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 09.29.2011
    EB-5 Investments: The New "Old" Alternative Finance Tool
    Updates
    Is it the result of turbulent economic times, tighter bank financing, or the globalization of the private finance and investment world? We cannot say for sure what is fueling the interest, but an increasing number of our clients are asking about, exploring or already gaining the benefits of the EB-5 Immigrant Investor Visa Program.
  • 09.22.2011
    Financial Services Bulletin: New Final Rule at the Fed and Proposed Rules at the SEC and CFTC
    Updates

    On Monday, September 19, 2011, the Securities and Exchange Commission proposed a new rule under the Securities Act of 1933 to implement the prohibition under Section 621 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 on material conflicts of interest in connection with certain securitizations.

  • 09.14.2011
    Financial Services Bulletin: New Amendments at the CFTC
    Updates
    On Monday, September 12, 2011, the Commodity Futures Trading Commission (the “CFTC”) amended its regulations governing off-exchange foreign currency transactions with members of the retail public (“retail forex transactions”).
  • 09.07.2011
    Financial Services Bulletin: New Final Rules at the CFTC, New Proposed Rules at the Fed, and the SEC Considers Regulatory Amendments
    Updates
    On Thursday, August 25, 2011, the Commodity Futures Trading Commission (the “CFTC”) adopted final rules and new forms to implement Section 23 of the Commodity Exchange Act (the “CEA”) as amended by Section 748 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).  Section 23, entitled “Commodity Whistleblower Incentives and Protection,” established a whistleblower program that requires the CFTC to pay an award, under regulations prescribed by the CFTC and subject to certain limitations, to eligible whistleblowers who voluntarily provide the CFTC with original information about a violation of the CEA that leads to the successful enforcement of a covered judicial or administrative action, or a related action.
  • 08.25.2011
    Financial Services Bulletin: the SEC and CFTC Request Public Input and the Fed Proposes Phase-In Period
    Updates
    On Friday, August 19, 2011, the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC”) approved for publication in the Federal Register a request for public comment in connection with a joint study on stable value contracts. Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) provides for the comprehensive regulation of swaps and security-based swaps and includes definitions of key terms relating to such regulation.
  • 08.17.2011
    Financial Services Bulletin: New Rules at the CFTC and the Fed
    Updates
    On Wednesday, August 10, 2011, the Commodity Futures Trading Commission (the “CFTC”) adopted final rules implementing new statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act'”). The Dodd-Frank Act provides that swaps in an “agricultural commodity” (as defined by the CFTC) are prohibited unless entered into pursuant to a rule, regulation, or order of the CFTC adopted pursuant to certain provisions of the Commodity Exchange Act (the “CEA”). The new rules implement regulations whereby swaps in agricultural commodities may transact subject to the same rules as all other swaps. The rules repeal and replace the CFTC’s current regulations concerning the exemption of swap agreements.
  • 08.04.2011
    Financial Services Bulletin: New Final and Proposed Rules at the CFTC, OCC and the Fed
    Updates
    On Wednesday, July 27, 2011, the Commodity Futures Trading Commission (the “CFTC”) adopted regulations and amended existing regulations to implement Sections 717, 718, 723, 728, 733, 745, 803, 804, and 806 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act'”). The CFTC amended its existing regulations governing the submission of new products, rules, and rule amendments. The final regulations establish the Commission's procedural framework for the submission of new products, rules, and rule amendments by designated contract markets, derivatives clearing organizations, swap execution facilities, and swap data repositories. In addition, the final regulations prohibit event contracts involving certain excluded commodities, establish special submission procedures for certain rules proposed by systemically important derivatives clearing organizations, and stay the certifications and the approval review periods of novel derivative products pending jurisdictional determinations.
  • 07.28.2011
    Financial Services Bulletin: New Rules at the OCC, CFTF and SEC
    Updates
    On Wednesday, July 20, 2011, the Office of the Comptroller of the Currency (the “OCC”) issued a final rule implementing Sections 312, 316, 322, 335, and 603 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). The rules incorporate the transfer to the OCC of certain functions of the Office of Thrift Supervision (the “OTS”). The rules also amend OCC rules pertaining to change in control of credit card banks and trust banks, deposit-taking by uninsured Federal branches, and OCC preemption and visitorial powers.
  • 07.26.2011
    D.C. Circuit Court Vacates Securities and Exchange Commission Proxy Access Rule
    Updates
    On July 22, 2011, the U.S. Court of Appeals for the D.C. Circuit issued its highly anticipated opinion in the challenge to SEC Rule 14a-11 brought by the Business Roundtable and the U.S. Chamber of Commerce. Rule 14a-11 would have required companies subject to the Exchange Act’s proxy rules to include in their proxy materials shareholder nominees for director who met specified conditions. In the strongly worded opinion, written by Judge Ginsburg, the court vacated Rule 14a-11, characterizing the SEC proxy access rule as “arbitrary and capricious” and stating that the SEC had failed “adequately to assess the economic effects” of Rule 14a-11. The court did not address the constitutional challenges raised by the plaintiffs under the First Amendment.
  • 07.21.2011
    Financial Services Bulletin: New Rules at the Fed and CFTC
    Updates
    On Thursday, July 14, 2011, the Federal Reserve Board approved a final rule repealing Regulation Q, which prohibits the payment of interest on demand deposits if the institution is a member of the Federal Reserve System.  This rule implements Section 627 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act").
  • 07.07.2011
    Financial Services Bulletin: Movement at the SEC, FFIEC and CFTC
    Updates
    On Tuesday, June 28, 2011, the Federal Financial Institutions Examination Council (FFIEC) issued supplemental guidance to the Authentication in an Internet Banking Environment, which was issued in October 2005.
  • 06.30.2011
    Financial Services Bulletin: Changes at the SEC and Final Interchange Rules at the Fed
    Updates
    On Wednesday, June 22, 2011, the SEC adopted amendments to the Investment Advisors Act, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). The amendments require advisors to hedge funds and other private funds to register with the SEC, expand disclosure requirements for investment advisors, revise pay-to-play rules, establish addition exemptions from SEC registration and reporting requirements for certain advisors, and reallocate regulatory responsibility between the various states and the SEC. There is a transitional exemption period requiring registration by March 30, 2012 for those advisors previously not required to do so.
  • 06.27.2011
    SEC Adopts Rule Defining “Family Offices” Under Dodd-Frank Act
    Updates
    At an open meeting of the Securities and Exchange Commission (SEC) on June 23, 2011, the SEC Commissioners approved a new rule defining “family offices.” Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) excluded family offices from the definition of investment adviser under the Investment Advisers Act of 1940 (Advisers Act) and thereby exempted family offices from the registration requirements under the Advisers Act, as amended by the Dodd-Frank Act. However, Section 409 of the Dodd-Frank Act also directed the SEC to adopt a rule defining the term “family office” in order to identify the entities eligible for the exclusion. On June 23, 2011, the SEC adopted such a rule.
  • 06.16.2011
    Financial Services Bulletin: New Rules at the Federal Reserve, SEC, FDIC and OCC
    Updates
    On Monday, June 13, 2011, the Federal Reserve Board adopted an interim final rule allowing small bank holding companies that are either S-corporations or organized in mutual form to exclude subordinated debt issued to Treasury under the SBLF, or Small Business Lending Fund, (as well as subordinated debt issued to Treasury under TARP) from treatment as "debt" for purposes of the Board's Small Bank Holding Company Policy Statement's debt-to-equity standard.
  • 05.27.2011
    Financial Services Bulletin: Proposed Rules by the OCC and SEC
    Updates
    On Wednesday, May 25, 2011, the Office of the Comptroller .of the Currency (the "OCC") proposed rules implementing Sections 312, 316, 322, 335, and 603 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). The proposed rules incorporate the transfer to the OCC of certain functions of the Office of Thrift Supervision. The OCC also is proposing amendments to its rules pertaining to change in control of credit card banks and trust banks; deposit-taking by uninsured Federal branches; and its preemption and visitorial powers rules.
  • 05.19.2011
    Financial Services Bulletin: Proposed Rules by the SEC, Federal Reserve and the CFTC
    Updates
    On Tuesday, May 10, 2011, the Securities and Exchange Commission (the "SEC") proposed a rule raising dollar thresholds required before investment advisers are able to charge their clients performance fees. This adjustment is required under Section 418 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act"), which requires the SEC to issue an order to adjust for inflation these dollar amount thresholds by July 21, 2011, and every five years thereafter.
  • 05.05.2011
  • 04.28.2011
    Financial Services Bulletin: The Fed, the CFTC and the SEC Take Action Under the Dodd-Frank Act Update
    Updates
    On Thursday, April 21, 2011, the Federal Reserve Board issued a request for public information and comment on two bankruptcy-related studies that it will conduct pursuant to Section 216 and Section 217 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
  • 04.21.2011
    Financial Services Bulletin: Federal Reserve Seeks Comment on Two Proposed Rules
    Updates
    On Friday, April 15, 2011, the Federal Reserve sought comment on a notice outlining the application of its consolidated supervisory program for bank holding companies to savings and loan holding companies for which it now has supervisory responsibility.
  • 04.14.2011
    Financial Services Bulletin: Algorithmic Descriptions, Swap Data Recordkeeping, Reporting, Margin and Capital Requirements, and Resolution Plan Reporting
    Updates
    On Friday, April 8, 2011, the CFTC and SEC released a joint study regarding the feasibility of requiring the derivatives industry to utilize algorithmic descriptions in order to describe financial derivatives.
  • 04.07.2011
    Financial Services Bulletin: Limit Up-Limit Down Proposals at the SEC and the Fed Proposes to Repeal Regulation Q
    Updates
    On Monday, April 5, 2011, the Securities and Exchange Commission (SEC) announced a proposal establishing the "limit up-limit down" mechanism aimed at curbing extraordinary market volatility in the U.S. equity markets.  The proposal was filed by national securities exchanges and the Financial Industry Regulatory Authority (FINRA).
  • 03.31.2011
    Financial Services Bulletin: Regulatory Reform Continues
    Updates
    On Friday, March 25, 2011, the Federal Reserve Board adopted two rules expanding the coverage of consumer protection in the areas of credit transactions and leases of higher dollar amounts.  The rules amend Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) and implement certain requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").  Protections will now be in place for credit transactions and consumer leases up to $50,000, as compared with $25,000 currently.  The amount will be adjusted annually to reflect any shifts in the consumer price index.
  • 03.24.2011
    Financial Services Bulletin: Spring Brings New Financial Regulatory Reform
    Updates
    On Tuesday, March 15, 2011, the Board of the Federal Deposit Insurance Corporation approved a Notice of Proposed Rulemaking ("NPR") to clarify the application of orderly liquidation authority under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act").
  • 03.17.2011
    Financial Services Bulletin: CFTC Proposes New Regulations, CPSS and IOSCO Issue Consultative Report, and Senators Introduce Bill Delaying Interchange Rule
    Updates
    On Wednesday, March 9, 2011, the Commodity Futures Trading Commission proposed amendments to its regulations regarding the registration of intermediaries.  These amendments are in-line with requirements under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").  The amendments incorporate references into the regulations to swap dealers, swap execution facilities, and major swap participants.
  • 03.10.2011
    Financial Services Bulletin: Financial Reform Continues towards Spring
    Updates

    On Tuesday, March 1, 2011, the Federal Reserve Board and the Federal Trade Commission proposed regulations regarding credit score disclosure.  The proposed regulations implement requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").  Proposed requirements include the "disclosure of credit scores and related information to consumers in risk-based pricing and adverse action notices under the Fair Credit Reporting Act if a credit score was used in setting the credit terms or taking adverse action."  The proposed regulations would amend Regulation V (Fair Credit Reporting) and Regulation B (Equal Credit Opportunity).  Comments on the proposed rules are due 30 days after publication in the Federal Register.

  • 02.17.2011
    Financial Services Bulletin: Continued Regulatory Reform
    Updates
    On Wednesday, February 9, 2011, the Federal Reserve Board approved a final rule implementing the conformance period relating to the so-called "Volcker Rule" under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act").  The Volcker Rule would prohibit banking entities from engaging in proprietary trading and from investing in or sponsoring hedge funds or private equity funds.  The final rule gives banking firms a period of time to conform their activities to the prohibitions and restrictions of the Volcker Rule.  The final rule will be effective April 1, 2011.
  • 02.10.2011
    Financial Services Bulletin: Recent Updates in Financial Regulatory Reform
    Updates
    On Wednesday, February 2, 2011, the SEC proposed rules that define security-based swap execution facilities and establish the facilities' registration requirements, duties, and core principles.  The SEC proposed these rules under the express direction under the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") to implement a regulatory framework for security-based swaps.
  • 01.28.2011
    Financial Services Bulletin: An Uptick of Regulatory Reform at the SEC and the Supreme Court Weighs in on Consumer Lending
    Updates
    On Friday, January 14, 2011, the SEC proposed a rule requiring security-based swaps dealers and major security-based swap participants "to provide to their counterparties a trade acknowledgment detailing information specific to the transaction."  Trade acknowledgements must be provided within 15 minutes, 30 minutes, or 24 hours of execution of the transaction, depending on whether the transaction is executed or processed electronically.  The new rule is proposed under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The rule is aimed at increasing transparency in the security-based swaps market.
  • 01.20.2011
    Financial Services Bulletin: 2011 Rings in with New Financial Reform
    Updates
    Washington State recently amended its definition of "accredited investor" to exclude the value of an investor's primary residence from the $1 million threshold calculation.  This change reflects the altered definition of "accredited investor" as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act.
  • 12.17.2010
    Financial Services Bulletin: Financial Reform Continues Through the End of the Year
    Updates
    On Tuesday, December 14, 2010, the Board of Directors of the FDIC approved an interagency rule implementing certain provisions of Section 171 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, commonly referred to as to the Collins Amendment.  The Collins Amendment requires capital requirements applicable to insured banks to "serve as floor for other capital requirements the agencies establish."  Basel II, as it is, allows for reductions in risk-based capital requirements below those applicable to insured banks, and will need to be altered.
  • 12.07.2010
    The Financial Reform Act: Flurry of SEC Rulemaking Offers Potential Answers for Advisers to Private Funds
    Updates
    On November 19, 2010, the Securities and Exchange Commission released two companion releases proposing new rules related to registration requirements for investment advisers to private funds, including hedge funds, private equity funds and other pooled investment vehicles.
  • 12.02.2010
    Financial Services Bulletin: Reform Continues with Recent Developments in Financial Services
    Updates
    On Tuesday, November 9, the Board of Directors of the Federal Deposit Insurance Corporation approved a final rule implementing section 343 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  Section 343 allows for temporary unlimited deposit insurance coverage for noninterest bearing transaction accounts.  This coverage will become effective on December 31, 2010 and will terminate on December 31, 2012.
  • 11.23.2010
    The Financial Reform Act: SEC Proposes a Definition of “Venture Capital Fund” for Purposes of Exemptions
    Updates
    On November 19, 2010, the Securities and Exchange Commission proposed a new rule, based on requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the Financial Reform Act, defining “venture capital funds” for purposes of exempting advisers to these funds from registering under the Investment Advisers Act of 1940.
  • 10.28.2010
    Financial Services Bulletin: New Rules at the FDIC and CFTC and the President's Working Group Releases Money Market Fund Report
    Updates
    On Tuesday, October 19, 2010, the Board of Directors of the FDIC approved a proposed long-range plan for deposit insurance fund management.  The proposal was created in response to the FDIC's altered authority under the Dodd-Frank Wall Street Reform and Consumer Protection Act
  • 10.21.2010
    Financial Services Bulletin: The SEC Proposes New Rules on Security Based Swap Transactions and Asset-Backed Securities
    Updates
    On Wednesday, October 13, 2010, the SEC adopted an interim rule requiring certain swap dealers to report security-based swaps entered into prior to the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act on July 21.
  • 10.15.2010
    Financial Services Bulletin: The Federal Reserve Sued over the Durbin Amendment, the FDIC Clarifies Orderly Liquidation Rules, and New Financial Sector Taxes in the EU
    Updates
    On Tuesday, October 12, 2010, Minnesota-based TCF Financial Corp. filed a lawsuit against the Federal Reserve in order to declare the Durbin Amendment, found in the Dodd-Frank Wall Street Reform and Consumer Protection Act, unconstitutional.  The Durbin Amendment allows the Federal Reserve to limit how much a bank with assets exceeding $10 billion can charge retailers when using a debit card.  TCF argues that the Durbin Amendment favors small banks and, therefore, violates the bank's right to equal protection.
  • 10.14.2010
    The Financial Reform Act: Defining a "Family Office" for Exemption Status
    Updates
    On October 12, 2010, the Securities and Exchange Commission proposed a new rule, based on requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the Financial Reform Act, defining “family offices” that will be excluded from regulation under the Investment Advisers Act of 1940.
  • 10.07.2010
    Financial Services Bulletin: Autumn Shows no Slowing of Financial Services Reform
    Updates
    On Monday, September 27, 2010, the FDIC Board of Directors approved a final rule extending through December 31, 2010 the Safe Harbor Protection for Treatment by the FDIC as Conservator or Receiver of Financial Assets Transferred by an Insured Depository Institution in Connection With a Securitization or Participation.  This final rule ensures that securitizations or participations in process before the end of 2010 will be permanently grandfathered under the existing terms of treatment.
  • 09.24.2010
    Investment Advisers, Take Note! Amendments to Form ADV Part 2 and Other Changes Resulting From the Financial Reform Act are Imminent
    Updates
    On July 28, 2010, the Securities and Exchange Commission adopted amendments to Part 2 of Form ADV, the form used by investment advisers to register with the SEC and state securities regulators.  These amendments are effective for filings made on or after October 12, 2010.  Also affecting advisers are changes made as a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, or the Financial Reform Act, which President Obama signed into law on July 21, 2010. Both the SEC's recent action and the Financial Reform Act make a variety of changes to the Investment Advisers Act of 1940.
  • 09.22.2010
    Financial Services Bulletin: Global Reform of Financial Services Continues
    Updates
    On Friday, September 17, 2010, the SEC proposed new rules requiring public companies to disclose information regarding short-term borrowing.  The new rules are designed "to enable investors to better understand whether amounts of short-term borrowings reported at the end of reporting periods are consistent with amounts outstanding throughout the reporting periods."  Enhanced disclosure would be included in the Management's Discussion and Analysis of Financial Condition and Results of Operations section of a public company's quarterly and annual reports and would include quantitative information for each type of short-term borrowing used as well as additional information to provide a context for the quantitative data.
  • 09.15.2010
    Financial Services Bulletin: SEC Approves New Circuit Breaker Rules and the Basel Committee Approves Higher Global Minimum Capital Requirements
    Updates
    On Friday, September 10, 2010, the SEC announced the approval of new rules submitted by the national securities exchanges and FINRA to expand circuit breaker rules to all stocks in the Russell 1000 Index and certain exchange-traded funds.
  • 08.24.2010
    The Financial Reform Act: Derivatives
    Updates
    Title VII of the Financial Reform Act, entitled "Wall Street Transparency and Accountability," substantially overhauls the regulation of the over-the-counter derivatives markets.  This Update provides highlights of the Financial Reform Act as it relates to derivatives.
  • 08.18.2010
    The Financial Reform Act: Section 1075 Changes the Rules Related to Credit and Debit Card Use
    Updates
    On June 30, 2010, the House of Representatives approved the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the Financial Reform Act, a comprehensive and expansive set of financial reforms widely thought to be the toughest changes to financial regulation in the United States since the Great Depression.
  • 08.16.2010
    The Financial Reform Act: New Offices of Minority and Women Inclusion Will Require Government Agencies to Focus on Diversity
    Updates
    On June 30, 2010, the House of Representatives approved the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the Financial Reform Act, a comprehensive and expansive set of financial reforms widely thought to be the toughest changes to financial regulation in the United States since the Great Depression.
  • 07.26.2010
    The Financial Reform Act: New Bureau of Consumer Financial Protection Is Established with Broad Rulemaking, Enforcement and Regulatory Authority
    Updates
    On June 30, 2010, the House of Representatives approved the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the Financial Reform Act, a comprehensive and expansive set of financial reforms widely thought to be the toughest changes to financial regulation in the United States since the Great Depression.
  • 07.26.2010
    The Financial Reform Act: Financial Reform Legislation Imposes New Requirements on Banks and Other Financial Institutions
    Updates
    On July 21, 2010, President Barack Obama signed into law the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the Financial Reform Act, declaring the Financial Reform Act to contain "the strongest consumer financial protections in history."
  • 07.22.2010
  • 07.21.2010
    The Financial Reform Act: New Corporate Governance, Executive Compensation and Proxy Voting Provisions Apply to All Public Companies
    Updates
    Congress has approved the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, and President Obama has signed it into law.
  • 07.21.2010
    The Financial Reform Act: Financial Reform Legislation Imposes New Requirements on Private Funds and Their Advisers
    Updates
    On June 30, 2010, the House of Representatives approved the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the Financial Reform Act, a comprehensive and expansive set of financial reforms widely thought to be the toughest changes to financial regulation in the United States since the Great Depression.
  • 07.15.2010
    Financial Services Bulletin: The Senate Passes the Dodd-Frank Bill, the FDIC Enhances Existing Backup Authorities over Insured Depository Institutions and Europe Approves Bankers' Bonus Rules and Proposes Changes to Existing European Consumer Protection Rules
    Updates
    On Thursday, July 15, 2010, the Senate approved the Dodd-Frank Bill by a vote of 60 to 39.  Having already passed the House, it is now anticipated that President Obama will sign the bill into law next week.
  • 07.01.2010
    Financial Services Bulletin: The Dodd-Frank Bill Conference Reopened and Modified Bill Approved by the House, the Fed Announces Changes to Payment System Risk Policy, the Bank of England Publishes Financial Stability Report, and European Parliament and the European Council Cap Bankers' Bonuses
    Updates
    On Tuesday, June 29, 2010, the conference committee that previously finalized the Dodd-Frank Bill reopened the conference in order to swap out a controversial $19 billion tax on large banks in favor of winding TARP down early and assessing modest fees through the FDIC.
  • 07.2010
    Articles

    Bank Director Magazine - 3rd Quarter 2010

  • 06.25.2010
    Financial Services Bulletin: The Dodd-Frank Bill
    Updates
    Early Friday morning, June 25, 2010, the House-Senate Conference reached final agreement on financial regulatory reform legislation, otherwise known as the Dodd-Frank Act of 2010. The Act, among other things, establishes a consumer financial protection entity, eliminates "too big to fail" bailouts, establishes a warning system to avoid systemic crises, and improves transparency and accountability for complex financial instruments as derivatives.
  • 06.24.2010
    Financial Services Bulletin: Financial Regulatory Reform, Clearly Erroneous Trades, and Incentive Compensation Regulation
    Updates
    The House-Senate Conference Committee continues to negotiate financial regulatory reform legislation. Both sides have put forth offers and counter offers in an effort to have the final legislation signed by the President before the July 4th recess.
  • 06.17.2010
    Financial Services Bulletin: Recent Developments in Financial Reform
    Updates
    On June 15, 2010, the House-Senate Conference committee began reconciling the two versions of financial regulatory reform legislation. The current timeline is to have the President sign a finalized bill by the July 4th recess.
  • 06.10.2010
    Financial Services Bulletin: European Derivatives Markets, a Financial Stabilization Mechanism for Europe, and the G-20's Commitment to Financial Regulatory Reform
    Updates
    On Wednesday, June 2, 2010, the Economic and Monetary Affairs Committee approved a resolution to toughen regulation regarding derivatives trading so as to "reduce speculative trading" and ensure that derivatives are traded openly and with uniform standards.
  • 06.03.2010
    Financial Services Bulletin: Taxation of Carried interest Legislation and regulation clarifications
    Updates
    On Friday, May 28, 2010, the House passed the American Jobs and Closing Tax Loopholes Act of 2010, H.R. 4213.  The bill passed by a vote of 215-204.
  • 05.27.2010
    Financial Services Bulletin: Senate Passes the Dodd Bill, Taxation of Carried Interest Legislation, and European Bank Resolution Funds
    Updates
    On Thursday Evening, May 20, 2010, the Senate passed the Restoring American Financial Stability Act of 2010.  The vote of 59 to 39 came with four Republicans voting in favor of the bill, and two Democrats voting against it.
  • 05.20.2010
    Financial Services Bulletin: Dodd Bill Developments, Amendments to the Dodd Bill, a Stock-by-Stock Circuit Breaker Rule Proposal, and a German Ban on Short-Selling
    Updates
    On Thursday, May 20, 2010, the Senate invoked cloture on the Restoring American Financial Stability Act of 2010.  The vote of 60-40 allows the Senate to move the bill to a final vote by the end of the week, although it can still be further amended before the final Senate vote.
  • 05.13.2010
    Financial Services Bulletin: European Bailouts, Regulatory Reform, and U.S. Exchange Rules
    Updates
    On Wednesday, May 5, 2010, Congressman Mike Pence (R-IN), Chairman of the House Republican Conference, and Conference Vice-Chair Cathy McMorris Rodgers (R-WA) sent a letter to Vice President Joe Biden, opposing an International Monetary Fund (IMF) bailout for Spain.
  • 04.29.2010
    Financial Services Bulletin: Regulatory Reform and Incorporation Transparency and Law Enforcement Assistance Act
    Updates
    On Wednesday, April 28, 2010, Senate Republicans finally agreed to allow the opening of the debate of the Restoring American Financial Stability Act of 2010.
  • 04.22.2010
    Financial Services Bulletin: Regulatory Reform, The Wall Street Transparency and Accountability Act, Allegations Against Goldman Sachs, and Financial Lessons Learned in Europe
    Updates
    On Friday, April 16, 2010, President Obama threatened to veto a Wall Street reform bill that fails to regulate the derivatives market.  The President stated that he “want[s] to see what emerges, but [he] will veto legislation that does not bring the derivatives market under control in some sort of regulatory framework and assures that we do not have the same sort of mess that we've seen in the past.”
  • 04.16.2010
    Financial Services Bulletin: Bernanke Discusses the Economic Crisis, an Extension of the Transaction Account Guarantee Program, and Proposed Rules Regarding Asset Backed Securities and the Deposit Insurance Assessment System
    Updates
    On Wednesday, April 7, 2010, Federal Reserve Chairman Ben Bernanke gave a speech at the Dallas Regional Chamber discussing the origins of the financial crisis, the Federal Reserve's policy responses, and both near term and longer term economic challenges facing the United States.
  • 04.01.2010
    Financial Services Bulletin: Investment Companies, Military Families, and Reaction to the Dodd Bill
    Updates
    On Thursday, March 25, 2010 the Securities and Exchange Commission announced that it is conducting a review to evaluate the use of derivatives by mutual funds, exchange-traded funds and other investment companies.
  • 03.25.2010
    Financial Services Bulletin: Covered Bonds, Financial Reform Legislation, Gift Cards, and a European Banking Framework for Times of Crisis
    Updates
    On Thursday, March 18, 2010, members of the House Financial Services Committee, Ranking Member of the Capital Markets Subcommittee, Scott Garret (R-NJ), along with support from Chairman Paul Kanjorski (D-PA) and Ranking Member Spencer Bachus (R-AL), introduced the United States Covered Bond Act.
  • 03.18.2010
    Financial Services Bulletin: The Dodd Bill: Restoring American Financial Stability Act of 2010
    Updates
    On Monday, March 15, 2010, Senator Christopher J. Dodd (D-CT), Chairman of the Senate Banking, Housing and Urban Affairs Committee, released a draft of a financial services reform bill entitled "Restoring American Financial Stability Act of 2010."  This legislative proposal is a companion to a similar bill that was passed by the House of Representatives in December 2009.
  • 03.04.2010
    Financial Services Bulletin: Recent Developments in Financial Regulatory Reform
    Updates
    On Thursday, February 25, the Technical Committee of the International Organization of Securities Commissions (IOSCO) published a template for the global collection of hedge fund information.  SEC Commissioner Kathleen Casey is the chair of the Technical Committee of IOSCO.  The IOSCO template is aimed at enabling “the collection and exchange of consistent and comparable data amongst regulators and other competent authorities for the purpose of facilitating international supervisory cooperation in identifying possible systemic risks in this sector.”
  • 02.25.2010
    Financial Services Bulletin: New Credit Card Rules Go Into Effect, the Fed Proposes Overdraft Rules Clarification, and the Volcker Rule Continues
    Updates
    On Friday, February 19, the Federal Reserve launched an informational website aimed at helping consumers understand the recent credit card rules, which took effect Monday, February 22.  The website helps consumers by summarizing the rules, promulgated as part of the Federal Reserve's implementation of provisions of the Credit Card Accountability, Responsibility and Disclosure Act of 2009 (Credit CARD Act), and explaining how they will affect credit card users.
  • 02.11.2010
    Financial Services Bulletin: Despite Heavy Snowfall, Financial Reform Moving Forward
    Updates
    The successive snow storms in Washington D.C. have limited the activity this week in Congress on financial services reform.  Nonetheless, on Tuesday, February 9, House Financial Services Committee Chairman, Barney Frank issued a statement regarding the financial industry and the need for increased consumer protection in the U.S. financial industry.
  • 02.04.2010
    Financial Services Bulletin: Regulatory Reform, Online Resources for Bank Directors, and Anti-Fraud Funding
    Updates
    On Wednesday, January 27, the SEC approved new rules aimed at reforming the regulation of money market funds in order to increase investor protection and curb risk. The approval provides for new rules and amends existing rules under the Investment Company Act of 1940.
  • 01.28.2010
    Financial Services Bulletin: Recent Developments in Financial Regulatory Reform
    Updates
    On Thursday, January 21, House Financial Services Committee Chairman Barney Frank (D-MA) released a memo clarifying uncertainties surrounding the Consumer Financial Protection Agency (CFPA).
  • 01.21.2010
    Financial Services Bulletin: The Federal Reserve Announces New Credit Card Rules
    Updates
    Last week, the Federal Reserve issued new rules regulating credit cards that go into effect February 22, 2010.  These consumer protective rules will affect credit card companies and consumers alike.
  • 2009 - 2010
    Financial Services Bulletin
    Updates
    With the recent flurry of legislative activity focused on reform of the regulatory framework for financial institutions and the financial markets, the Perkins Coie Financial Services Practice is pleased to bring you the Financial Services Bulletin. This bulletin highlights recent legislative activity impacting financial services and financial institutions. The group plans to publish future bulletins as new legal developments are announced.
  • 12.17.2009
    Financial Services Bulletin: Wall Street Reform and Consumer Protection Act
    Updates
    On Friday, December 11, 2009, the House passed the extensive Wall Street Reform and Consumer Protection Act.  The Wall Street Reform Act, as proposed to the floor of the House and aimed at financial regulatory reform, was discussed in our December 11, 2009 Financial Services Bulletin.
  • 12.11.2009
    Financial Services Bulletin: Wall Street Reform and Consumer Protection Act
    Updates
    On Wednesday, December 2, 2009, the House Financial Services Committee finished working on a comprehensive set of legislative initiatives aimed at financial regulatory reform, which are reflected in The Wall Street Reform and Consumer Protection Act (H.R. 4173).
  • 12.03.2009
    Financial Services Bulletin: Financial Stability Improvement Act and the Federal Insurance Office Act
    Updates
    On Wednesday, December 2, 2009, the House of Representatives Financial Services Committee passed two significant acts, the Financial Stability Improvement Act and the Federal Insurance Office Act, both of which are aimed at further regulation of the financial services sector.  Both bills have been referred to the full House for consideration.  Below are brief summaries of the acts and links to the legislative text.
  • 11.19.2009
    Financial Services Bulletin: Financial Reform Bills
    Updates
    On Tuesday, November 10, 2009, Senator Dodd (D-CT), Chairman of the Senate Banking Committee, released a draft of a financial services reform bill, entitled "Restoring American Financial Stability Act of 2009."  This legislative proposal is a companion to a similar, albeit less extensive, version that has been introduced in the House of Representatives.
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