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Is the SEC’s Proposed “Best Interest” Standard for Broker-Dealers in Anyone’s Best Interest?

USA - May 16 2018 Proposal seeks to clarify and enhance obligations applicable to a broker-dealer’s retail customer interactions, but may raise more questions than...

Dana G. Fleischman, Stephen P. Wink, Brett M. Ackerman.


Volcker Rule: an initial look at significant changes

USA - December 23 2013 On December 10, 2013 the US federal banking agencies, along with the Securities and Exchange Commission (SEC) and the Commodity Futures Trading...

Ellen L. Marks, Alan W. Avery, Gitanjali P. Faleiro, Pia Naib.


CFTC “relief” for clearing and reporting of inter-affiliate swaps few are relieved

USA - April 30 2013 The US Commodity Futures Trading Commission (CFTC) recently granted two forms of regulatory relief for swaps between affiliated entities, but...

Ellen L. Marks, Peter Y. Malyshev, Jonathan T. Ammons, Alan W. Avery, Brett M. Ackerman.


CFTC issues further extraterritoriality guidance and relief for cross-border swaps

USA - January 17 2013 On January 7, 2013, the US Commodity Futures Trading Commission (CFTC) published a time-limited final order (the Final Order)1 exempting certain...

Stephen P. Wink, Ellen L. Marks, Peter Y. Malyshev, Jonathan T. Ammons, Alan W. Avery.


Federal Reserve releases proposed rules for enhanced prudential standards for foreign banking organizations

USA - December 21 2012 This Client Alert provides an overview and summary of key requirements of the proposed rules issued on December 14, 2012 by the Board of Governors of the Federal Reserve System (Federal Reserve) to implement the enhanced prudential standards and early remediation requirements of Section 165 and 166 of the Dodd- Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) for foreign banking organizations1 and foreign nonbank financial companies designated for supervision by the Federal Reserve (FBO Proposal)....

Melissa R. H. Hall, Alan W. Avery.