Mapping the Landscape of Comments to the SEC’s New Proxy Rules

By Jens Frankenreiter March 4, 2020 by renholding

In November 2019, the Securities and Exchange Commission (“SEC”) issued a notice of proposed rulemaking aimed at the roles played by proxy advisers in providing information and voting recommendations to clients. The move was preceded by substantively similar interpretive guidance …

SEC Chair Talks Rulemaking Over the Past Year and the Road Ahead

By Jay Clayton December 7, 2018 by renholding

For many, December is a time to reflect on the past year and to look forward to what the New Year may bring. I believe organizations also should mark milestones, take stock of what has been done and what needs

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SEC Chair Talks Investor Roundtables on Conduct Standards for Investment Professionals Rulemaking

By Jay Clayton August 23, 2018 by renholding

In April 2018, the Commission proposed for public comment a significant rulemaking package designed to serve our Main Street investors that would (1) require broker-dealers to act in the best interest of their retail customers, (2) reaffirm and in some

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Taking Investor Preferences Seriously

By Kathryn Judge July 11, 2018 by renholding

Over the last half century, finance has made remarkable progress explaining the pricing of financial assets. In relying on portfolio theory, however, mainstream pricing models tend to ignore investor preferences for certain asset types. This is a mistake. In a …

The Rise of Financial Regulation by Settlement

By Matthew C. Turk September 12, 2017 by renholding

The dramatic escalation in enforcement activity by federal agencies against large financial institutions since the financial crisis is well known. These days the latest multi-billion dollar deal between regulators and Wall Street banks has lost blockbuster status and hardly even …

Morrison & Foerster’s Initial Take on the CFPB’s Debt Collection Outline

By Donald C. Lampe, Jeremy R. Mandell and Calvin D. Funk August 25, 2016 by renholding

On July 28, 2016, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued its outline of proposals under consideration for the regulation of debt collection. This 117-page release, entitled “Small Business Review Panel for Debt Collector and Debt Buyer Rulemaking: …

Shearman & Sterling discusses SEC’s Proposal to Revamp its Mining Disclosure Requirements

By Richard J.B. Price, Jonathan Handyside, Cynthia Urda Kassis and Jason R. Lehner July 19, 2016 by ilyabeylin

On June 16, 2016, the US Securities and Exchange Commission (“SEC”) issued a proposed rule (available here), which, if adopted, would result in a revamp of its disclosure requirements for mining company issuers. The proposed rule is intended to …

Cost-Benefit Analysis and the Conflict Minerals Rule

By Jeff Schwartz and Alexandrea Nelson March 15, 2016 by ilyabeylin

In § 1502 of Dodd-Frank, Congress instructed the SEC to draft rules requiring public companies to disclose their use of “conflict minerals” originating in and around the Democratic Republic of the Congo (DRC). Coined the Conflict Minerals Rule, the statute …

Gibson Dunn analyzes the CFPB’s Rulemaking to Curtail Arbitration Agreements Barring Class Actions in Consumer Financial Contracts

By Douglas R. Cox, Jason J. Mendro and Chantale Fiebig October 21, 2015 by jbarrowscls

On October 7, 2015, the United States Consumer Financial Protection Bureau announced that it is “launch[ing] a rulemaking process” that is intended to impede the use of “pre-dispute arbitration agreements for consumer financial products and services.”[1] The proposal currently …

Davis Polk’s Dodd-Frank Progress Report April 2013

By Margaret E. Tahyar and Gabriel D. Rosenberg April 3, 2013 by Jason Parsont

On April 1, Davis Polk & Wardwell LLP released its April 2013 Dodd-Frank Progress Report, which can be found here. Davis Polk issues these Progress Reports monthly to update the market on the progress of the rulemaking required under …

Davis Polk’s Dodd-Frank Progress Report March 2013

By Margaret E. Tahyar and Gabriel D. Rosenberg March 12, 2013 by Jason Parsont

On March 1, Davis Polk & Wardwell LLP released its March 2013 Dodd-Frank Progress Report, which can be found here. Davis Polk issues these Progress Reports monthly to update the market on the progress of the rulemaking required under …

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Rulemaking