Samuel E. Proctor

Debevoise & Plimpton discusses the Proposed Leverage Coverage Ratio (LCR) Rule

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The following is based on a memo from Debevoise & Plimpton, published on November 1, 2013, which is available here.  The original memo contains a useful graphic representation of the LCR equation which has been omitted from this post.

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Debevoise discusses SEC Amendments to Financial Responsibility and Custody Rules

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On July 30, the Securities and Exchange Commission (the “SEC”) adopted new rules with respect to broker-dealer financial responsibility and custody. The rules came in two separate rulemakings. The first concerns amendments to SEC Rules 15c3-1 and 15c3-3 (and related

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