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OCC and FDIC Proposed Rules Seek to Neutralize Madden Holding and Restore “ValidWhen-Made” Principle

USA - December 2 2019 On November 18, 2019, the Department of the Treasury's Office of the Comptroller of the Currency ("OCC") issued a notice of proposed rulemaking (the...

Andrew Keller, Deborah Festa, Douglas Landy.

Part 2 Blockchain and the Volcker Rule: Are Cryptocurrency Companies Covered Funds?

USA - September 25 2018 We last wrote about how the Volcker Rule's1 ban on Proprietary Trading impacts the ability of banking entities to buy and sell certain...

Catherine Leef Martin, Jonathan Edwards, Douglas Landy.

Bitcoin and the Volcker Rule: Are Banks Banned from Cashing in on the Crypto Craze?

USA - May 16 2018 Over the past year, Bitcoin and other virtual currencies (often referred to as "cryptocurrencies") have skyrocketed in price and greatly increased...

Jonathan Edwards, Douglas Landy.

CCPs as Third Party Service Providers: Breach notification issues

USA - April 23 2018 Among the requirements placed on New York chartered- or licensed-financial institutions is that, pursuant to Section 500.17 (“Notices to the...

Joel Harrison, Nicholas Smith, Douglas Landy, John Williams.

Financial Market Utilities: the Unintended Consequences of H.R. 10, the Financial CHOICE Act, or It is key to be a QCCP under Basel 3

USA, Global - June 29 2017 On June 8, 2017, the House of Representatives passed H.R. 10, the Financial CHOICE Act of 2017 ("H.R. 10"). 1 Subtitle D, entitled "Eliminating...

Douglas Landy, John Williams.