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Today [February 8], the Commission voted to adopt amendments to Form PF, an important reporting tool whereby the Commission and the Financial Stability Oversight Council (FSOC) receive reporting from private fund advisers. I am pleased to support the adoption because
FSOC
Davis Polk Discusses the FSOC Annual Report
The Financial Stability Oversight Council released its 2023 Annual Report, highlighting its 2023 activities, significant financial market and regulatory developments and potential emerging threats to U.S. financial stability. The 2023 Annual Report newly identifies artificial intelligence and insurance as vulnerabilities …
Davis Polk Discusses FSOC Revision to Nonbank SIFI Designation Framework
The Financial Stability Oversight Council revised its interpretive guidance and analytic framework for FSOC’s authority to designate nonbank financial companies for Federal Reserve supervision and regulation and to otherwise monitor and respond to financial stability risks. These changes reverse key …
Sullivan & Cromwell Discusses Revised FSOC Guidance on Nonbank SIFI Designations
SEC Chair Gensler Delivers Remarks on LIBOR Before the Financial Stability Oversight Council
Thank you, Secretary Yellen. Thank you to all of my colleagues—not only at this table but around the globe—for their hard work putting an end to the London Interbank Offered Rate (LIBOR)
LIBOR was an innovation of the 1970s to
Davis Polk Discusses FSOC Proposals on Nonbank SIFIs
The Financial Stability Oversight Council unanimously approved two proposals for public comment regarding FSOC’s authority to designate nonbank financial companies for Federal Reserve supervision and regulation, as summarized in our deck. These proposals would reverse key aspects of changes made …
SEC Commissioner Dissents from New Rule on Private Fund Data Collection
Thank you, Chair Gensler. This expansion of Form PF data collection is the latest reflection of the Commission’s unquestioning faith in the Benevolent Power of More, a faith that I do not share. We have not explained sufficiently why we
SEC Chair Speaks on New Rule for Private Fund Data Collection
Today [May 3], the Commission considers adopting a final rule amending Form PF, an important tool that the Commission uses to oversee private fund advisers. I am pleased to support the amendments because they will improve visibility into private funds,
The FTX Collapse: Why Did Due Diligence, Regulation, and Governance Evaporate?
FTX[1] is a Bahamas-based cryptocurrency exchange founded in 2019 that, at its peak in 2021, had over 1 million users, making it the world’s third largest crypto exchange by volume. Since November 11, 2022, though, FTX has been in …
Davis Polk Discusses FSOC Report on Financial Stability Risks of Digital Assets
The report recently issued by the Financial Stability Oversight Council (FSOC) is quite different from the other reports published so far by the U.S. financial regulators in response to Executive Order 14067 on digital assets (FSOC Report).1 Helpfully, this …
SEC Chair Gensler on Proposed Joint Amendments to Form PF
Today [August 10], the Commission is considering whether to propose joint amendments with the Commodity Futures Trading Commission (CFTC) to Form PF, an important reporting tool that the Commission and the Financial Stability Oversight Council (FSOC) use, respectively, to protect
SEC Chair Gensler Speaks to FSOC on Money Market Funds, Open-End Bond Funds, and Hedge Funds
Thank you, Secretary Yellen, for focusing the Council’s attention on financial resiliency with regard to three key parts of our capital markets — particularly money market funds, open-end bond funds, and hedge funds.
The fund industry gives retail and institutional
Davis Polk Discusses Developments in Regulation Related to Private Equity
Rules and regulations
SEC proposes amendments to bolster private fund reporting
On January 26, 2022, the Securities and Exchange Commission (SEC) voted to propose certain amendments to Form PF designed to facilitate the SEC’s oversight of private fund advisers and …
Climate-Risk Disclosures and “Dirty Energy” Transfers: “Progress” Through Evasion
At first glance, recent progress towards transparency in corporate climate-risk disclosures seems exceptional. Over 2,000 companies now publish annual reports showing their carbon emissions data (although most self-interestedly omit Scope 3 data). Many (including most recently ExxonMobil) have made a …
Fragile Financial Regulation
As COVID-19 rocked financial markets in March 2020, the Treasury market failed to perform its role of maintaining financial stability. Unable to respond to the surge of investors liquidating their Treasury holdings to raise cash, the secondary market ground to …
Reforming the Macroprudential Regulatory Architecture in the United States
When the COVID-19 pandemic shuttered major economies in March 2020, it also wreaked havoc on financial markets. In the first few weeks of March, investment-grade corporate bonds lost roughly a fifth of their value, on par with the declines in …
Resurrecting the Office of Financial Research
The Office of Financial Research (“OFR”) was created by the Dodd-Frank Act to help address the gaps in data availability and analysis that had hampered governmental authorities in their response to the financial crisis of 2008. It was hoped that …
Presidential Pendulums in Finance
While much attention has been paid to President Trump’s deregulatory efforts and intentions, presidential involvement in the work of the administrative agencies is not new. Past presidents including Ronald Reagan, Bill Clinton, and Barack Obama have acted up to – …
Coronavirus, Systemic Risk, and Lessons from 2008
The greatest single-day decline in the stock market this century, widespread fear and uncertainty, shuttered schools, an end to large gatherings everywhere from NBA games to the South by Southwest festival – these are just a few of the signs …
Davis Polk Discusses FSOC’s Shift to an Activities-Based Approach
The Financial Stability Oversight Council’s (FSOC) recently revised guidelines (the 2019 Guidelines)[1] on how it will identify and address financial stability risks are a major shift from the guidelines it issued in the immediate aftermath of …