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 …

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 …

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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 …

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SEC Releases Report on Regulation S-K’s Disclosure Requirements

On December 20, 2013, the Securities and Exchange Commission released a report, required by Section 108 of the JOBS Act, that reviews the disclosure requirements in Regulation S-K.   The report summarizes the Commission’s prior initiatives, reviews the current disclosure requirements, …

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Morrison & Foerster discusses CFTC Speculative Position Limits Proposal

On November 5, 2013, the Commodity Futures Trading Commission (“CFTC” or “Commission”) proposed new speculative position limits. The proposal (“New Proposal”) would establish spot-month and non-spot-month limits for 28 core physical commodity contracts and their “economically equivalent” futures, options, and

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Why Have No High Level Executives Been Prosecuted In Connection With The Financial Crisis?

The following comes to us from the Honorable Judge Jed S. Rakoff, who sits in the U.S. District Court for the Southern District of New York.  Judge Rakoff is also an adjunct professor at Columbia Law School and will be

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Federal Reserve Proposes Bank Liquidity Requirements That Exceed the Basel III Standard

The following post is based on a memo originally published by Skadden, Arps, Slate, Meagher and Flom LLP & Affiliates on October 24, 2013.

The Federal Reserve Board (Board) today approved a proposed rule requiring larger U.S. banking organizations maintain …

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