The Marketplace of Ideas: Should the SEC change the rules on blockholder disclosure?

The CLS Blue Sky Blog presents Part II of the third installment of our series, “The Marketplace of Ideas.” Earlier installments on different topics are available here and hereThe intent is to present different perspectives on the same Read more

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Editor's Tweet: The Marketplace of Ideas: Rethinking the Disclosure of Beneficial Ownership under Section 13(d) Part II http://wp.me/p2Xx5U-1CQ

Ropes & Gray on Trade Execution Mandate for Certain Interest Rate Swaps

The Commodity Futures Trading Commission (“CFTC”) Division of Market Oversight (the “Division”) announced yesterday that Javelin SEF, LLC’s (“Javelin”) self-certification of available-to-trade determinations (“MAT Determinations”) for certain benchmark interest rate swap contracts is deemed certified. Under CFTC regulations, the swaps … Read more

Milbank discusses Title VII and the Volcker Rule: Same swap, different rules

Now that the final rule[1] implementing Section 619 of the Dodd-Frank Act,[2] commonly known as the “Volcker Rule,”[3] has been implemented, banking entities engaged in swaps activities must plan how they will navigate the two different and overlapping regulatory regimes

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Clifford Chance on Exemptions for Inter-Affiliate and Intragroup Transactions Under Dodd-Frank and EMIR

On January 16, 2014, Clifford Chance released a briefing, available  here, on exemptions for inter-affiliate and intragroup transactions under the U.S. Dodd-Frank Act and the European Market Infrastructure Regulation (“EMIR”).  Both impose obligations requiring the clearing and reporting of … Read more

ian ayres

Why the CFPB’s Qualified Mortgage Rule Misses the Mark

This post grows out of two working papers (downloadable here and here) that Professor Ayres wrote with Joshua Mitts, a former student who is now working at Sullivan & Cromwell.

On Friday, January 10th, the Consumer Financial Protection Bureau’s … Read more

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Editor's Tweet: Why the CFPB’s Qualified Mortgage Rule Misses the Mark http://wp.me/p2Xx5U-1JF

Alston & Bird on Practical Considerations for the Customer of Dodd-Frank Rule on Segregation of Margin for Uncleared Swaps

The following post is based on a memo originally published by Alston & Bird LLP on January 13, 2014. The original publication can be accessed here.

As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the … Read more

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Editor's Tweet: Practical Considerations for the Customer of Dodd-Frank Rule on Segregation of Margin for Uncleared Swaps http://wp.me/p2Xx5U-1IV
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The Volcker Rule Prohibitions on Proprietary Trading: Considerations for Broker-Dealer Affiliates of Foreign Banking Organizations

The Volcker Rule imposes significant restrictions on “proprietary trading” by banking organizations and their affiliates. The purpose of this Memorandum is to discuss how these restrictions may impact broker-dealer affiliates of foreign banking organizations that conduct business in the United

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Davis Polk Discusses OCC’s Risk Governance Guidelines for Banks

The OCC has proposed a set of enforceable and specific risk governance guidelines to formalize its heightened expectations for large national banks and federal savings associations. The risk governance guidelines would set new, and much higher, minimum standards for the … Read more

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Editor's Tweet: Davis Polk Discusses OCC's Risk Governance Guidelines for Banks