SEC issues no-action letter addressing registration requirements for certain advisory affiliates *

USA - February 13 2012
The staff of the Securities and Exchange Commission (the “Commission”) issued a no-action letter on January 18, 2012 to the American Bar Association’s Subcommittee on Hedge Funds clarifying the registration requirements for certain related entities under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).

Co-authors: Drew G.L. Chapman , Steven D. Lofchie, Zahra F. Zaidi .

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Changes to the regulation of broker-dealers and investment advisers under Title IX of the Dodd-Frank Wall Street Reform and Consumer Protection Act *

USA - August 12 2010
Part I of this memorandum focuses on Title IX of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act") as it relates to the regulation by the Securities and ExchangeCommission ("SEC") of broker-dealers and, to a lesser extent, investment advisers.

Co-authors: James McDonnell, Steven D. Lofchie, Jeffrey L. Robins, Glen Barrentine.

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Changes to the regulation of banks, thrifts, and holding companies under the Dodd-Frank Wall Street Reform and Consumer Protection Act *

USA - July 20 2010
The focus of this Memorandum is on the material changes to U.S. banking regulation made by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act” or the “Dodd-Frank Act”), including the potential regulation by the Board of Governors of the Federal Reserve System of nonbank financial companies deemed systemically significant.

Co-authors: Scott A. Cammarn , Steven D. Lofchie, Bryan Shipp.

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Some concerns with the regulation of large non-bank holding companies *

USA - June 3 2010
The Wall Street Reform and Consumer Protection Act of 20091 (the "House bill") and the Restoring American Financial Stability Act of 2010 (the "Senate bill"2; and together with the House bill, the "Legislation") both contain a requirement that large financial firms that do not own banks ("Non-BHCs") should be regulated as if they were bank holding companies ("BHCs").

Co-authors: Steven D. Lofchie, Richard M. Schetman, Bryan Shipp.

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The FDIC’s Statement of Policy on Qualifications for Failed Bank Acquisitions *

USA - August 31 2009
The Board Of Directors of the Federal Deposit Insurance Corporation ("FDIC") has adopted its final Statement of Policy on Qualifications for Failed Bank Acquisitions (the "Acquisition Policy Statement") by a 4-1 vote.

Co-authors: Steven D. Lofchie, Julius L. Loeser, Bryan Shipp.

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