Insights from Winston & Strawn Feature: Bipartisan Senate Bill Provides Regulatory Relief to Regional Banks FINRA Banking Agency Developments Treasury Department Developments Securities and Exchange Commission Federal Rules Effective Dates Exchanges and Self-Regulatory Organizations Industry News Winston & Strawn Upcoming Events & Speaking Engagements Winston & Strawn Publications VOLUME 12, NO. 38 October 9, 2017 Insights from Winston & Strawn The Securities and Exchange Commission (SEC) issued 16 new ADV FAQs on September 29, 2017, two days before the revised form ADV took effect. Form ADV is the uniform form used by investment advisers to register with both the SEC and state securities authorities. Registered investment advisers now have to provide more client account data and social media information in a revised ADV. The changes were designed to increase the amount of data the SEC collects so it can better monitor potential systemic market risks. The new ADV FAQs are intended to help registered investment advisers better understand the changes to the ADV. It addresses questions on a multitude of topics most notably—form ADV Items 1.F, 5.D, 7.A, and 7.B. The new ADV FAQs clarify that when completing Item 1.F registered investment advisers may list more than 25 offices. However, Item 1.F only requires that the largest 25 offices conducting advisory business be listed, in addition to the adviser’s principal office and place of business. Likewise, Item 1.F.(5) requires he or she to disclose (without individually listing) the total number of offices, other than his or her principal office and place of business, at which he or she conducts investment advisory business as of the end of the most recently completed fiscal year. Further, when filling out Section 5.D the new ADV FAQ instructs a registered investment adviser to count clients the way he or she “normally” counts them for his or her firm. The SEC recognizes that some advisers “treat multiple members of the same family” as a single client, while others would tabulate the same situation as two or more clients. When counting clients, a registered investment adviser may rely on Rule 202(a)(30)-1 which provides a safe harbor to those who are relying on the foreign private adviser exemption of the Investment Advisers Act of 1940. Finally, should an advisor lack any clients in a given category in a column under Item 5.D. (1), the SEC courages he or she to report zero. The new ADV FAQs also advise when to disclose certain information regarding an adviser’s “advisory affiliates,” which is defined to include all persons directly or indirectly controlled by the adviser, in the following scenario. A firm counsels private fund clients, the investors in which are predominantly not the firm’s related persons. The private funds the firm counsels may take a significant ownership interest in an issuer that is an operating company, and persons associated with the firm may participate in the management of the issuer in connection with the investment. As a result, the firm may “control” the operating company. The new ADV FAQs reveal that the SEC will not “recommend enforcement action to the Commission under Section 207 of the Advisers Act if the firm does not treat operating companies as advisory affiliates (i) for purposes of Item 7 of Part 1A and Item 10 of Part 2A, unless [the] firm has a business relationship with an operating company unrelated to a fund’s investment that otherwise creates a conflict of interest between [the] firm and the fund or (ii) for purposes of Item 11 of Part 1A.” Similarly, in regard to Item 7.A, a registered investment adviser can omit a related person from Section 7.A if he or she “(1) have no business dealings with the related person in connection with advisory services [he or she] provide to [his or her] clients; (2) do not conduct shared operations with the related person; (3) do not refer clients or business to the related person, and the related person does not refer prospective clients or business to [him or her]; (4) do not share supervised persons or premises with the related person; and (5) have no reason to believe that [his or her] relationship with the related person otherwise creates a conflict of interest with [his or her] clients.” Employees who perform investment advisory functions or are registered representatives of a broker-dealer can also be omitted from the disclosure in Item 7.A. Yet, if a firm has a related person (employee, director, etc.) who has a separate business as an investment adviser or broker-dealer, it must report that business in response to Item 7.A. Additionally, the new ADV FAQs provide that if an adviser seeks to preserve the anonymity from the Commission of the name of a private fund to which he or she provides investment advisory services in Item 7.B, he or she must maintain all of the books and records required under rule 204-2 using the same designation to identify the private fund client. The new ADV FAQs provide insight to a number of other questions raised by the revised Form ADV. A complete list of all ADV FAQs can be found at https://www.sec.gov/divisions/investment/iard/iardfaq.shtml. The end of September also saw the introduction of a bipartisan Senate bill addressing systematic risk, explained in more detail below. While the bill known as the Systemic Risk Designation Improvement Act reflects ideas that have been discussed robustly over the last year, it’s not at all clear how much support it will garner. Lauren Randle Feature: Bipartisan Senate Bill Provides Regulatory Relief to Regional Banks On September 28, 2017, U.S. Senator David Perdue (R-Ga.) and U.S. Senator Claire McCaskill (D-Mo.) introduced a bipartisan Senate bill, known as the Systemic Risk Designation Improvement Act or the PerdueMcCaskill bill (the “bill”), which would allow the Federal Reserve to provide regulatory relief to small regional banks that have more than $50 billion in assets but do not threaten global financial risk in case they fail. Such regional banks are currently subject to burdensome regulations put in place by the Dodd-Frank Act, including reporting requirements, limits on lending, and limits on mergers and acquisitions. Pursuant to the bill, the $50 billion asset threshold would be removed and substituted with criteria that would not just look at asset size, but also interconnectedness, substitutability, global cross-jurisdictional activity, and complexity. Sen. Perdue, a member of the Senate Banking Committee (“committee”), commented in a press release that “[r]egional banks offer a lifeline to small businesses and entrepreneurs looking to create jobs.” He added that the bill “would actually test banks for systemic risk rather than forcing banks to comply with an arbitrary figure.” Sen. McCaskill stated in the same press release that “[t]his is a commonsense fix that’ll untie the hands of our small regional banks and return to them the flexibility to lend to Missouri customers who want to buy a house, or start a business.” She referenced remarks by former House Financial Services Committee Chairman Barney Frank (D-Mass.), who admitted that the $50 billion asset threshold might not be the best measure to define which banks should be subject to tougher regulations. American Bankers Association Executive Vice President James Ballentine praised the bill, finding that it “recognizes that arbitrary size thresholds are needlessly burdensome, increase costs and reduce products and services available to bank customers.” He pointed out that “[t]he most effective and value-added supervision system is one that is tailored and takes into account a broader view of bank characteristics, including asset size, business model and risk profile,” remarking that this “legislation takes an important step toward reforming our financial regulatory system, and we look forward to working with lawmakers to move it forward.” FINRA – Regulatory Matters at a Glance Please click here to view a summary of the regulatory notices, rule filings, guidance and the like published by the Financial Industry Regulatory Authority (“FINRA”) during the previous month. Banking Agency Developments OCC T+2 Securities Transaction Settlement Cycle: Notice of Proposed Rulemaking On October 6th, the Office of the Comptroller of the Currency (“OCC”) announced that it is requesting comment on a proposed rule to shorten the standard settlement cycle for securities purchased or sold by national banks or federal savings associations. The proposal was issued jointly with the Federal Deposit Insurance Corporation. The proposal was published in the Federal Register on September 11, 2017. The comment period for the proposed rule ends on October 11, 2017. Acting Comptroller of the Currency Rescinds Deposit Advance Product Guidance On October 5th, Acting Comptroller of the Currency Keith A. Noreika announced that he has approved rescission of the agency’s Guidance on Supervisory Concerns and Expectations Regarding Deposit Advance Products that was published in the Federal Register on November 26, 2013, and accompanying OCC Bulletin 2013-40. OCC Hosts Credit Risk and Operational Risk Workshops in Louisville On October 5th, the OCC announced that it will host two workshops at the Holiday Inn Louisville Airport, Louisville, Ky., November 14-15, for directors of national community banks and federal savings associations supervised by the OCC. The Credit Risk workshop on November 14th will focus on credit risk within the loan portfolio, such as identifying trends and recognizing problems. The workshop will also cover the roles of the board and management, how to stay informed of changes in credit risk, and how to effect change. The Operational Risk workshop on November 15th will focus on the key components of operational risk (people, processes, and systems) and will also cover governance, third-party risk, vendor management, and cybersecurity. Acting Comptroller Discusses Efforts to Reduce Regulatory Burden and Expand Economic Opportunity On October 5th, Acting Comptroller of the Currency Keith A. Noreika discussed efforts to reduce regulatory burden and expand economic opportunity. During his remarks before a group of midsize bank risk officers, the Acting Comptroller also highlighted risks facing those banks and the federal banking system. FDIC Results of Summary of Deposits Survey On October 3rd, the FDIC announced that it has released the results of its annual survey of branch office deposits for all FDIC-insured institutions. Federal Reserve Comment Period Extended on Proposals to Enhance Effectiveness of Boards of Directors at Banks and New Rating System for Large Firms On October 5th, the Federal Reserve Board announced that it has extended until November 30, 2017, the comment periods for its proposal to enhance the effectiveness of boards of directors, as well as its related proposal to implement a new ratings system for large financial institutions that would be aligned with the postcrisis supervisory program. CFPB CFPB Finalizes Rule to Stop Payday Debt Traps On October 5th, the Consumer Financial Protection Bureau (“CFPB”) announced that it has finalized a rule that is aimed at stopping payday debt traps by requiring lenders to determine upfront whether people can afford to repay their loans. These protections cover loans that require consumers to repay all or most of the debt at once, including payday loans, auto title loans, deposit advance products, and longer-term loans with balloon payments. The rule also curtails lenders’ repeated attempts to debit payments from a borrower’s bank account, a practice that racks up fees and can lead to account closure. See Fact Sheet Summarizing CFPB Rule on Payday Loans. Click Here for Prepared Remarks of CFPB Director Richard Cordray on the Payday Rule Press Call.Also see New York Times Article on the New Rule. CFPB Issues Interim Final Rule and Proposed Rule to Help Mortgage Servicers Communicate With Certain Borrowers at Risk of Foreclosure On October 4th, the CFPB announced that it has issued an interim final rule and a proposed rule to provide mortgage servicers more flexibility and certainty around requirements to communicate with certain borrowers under the Bureau’s 2016 mortgage servicing amendments. The interim final rule becomes effective on Oct. 19, 2017, the same date that the related 2016 rule provisions become effective. The proposed effective date for the proposed rule is April 19, 2018, the same date that the sections of the 2016 rule that the proposal would amend become effective. The comment period on both the interim final rule and the proposed rule will close 30 days after publication in the Federal Register. Treasury Department Developments Treasury Releases Second Report on the Administration’s Core Principles of Financial Regulation On October 6, 2017, the U.S. Department of the Treasury announced that it has released a report detailing how to streamline and reform the U.S. regulatory system for the capital markets. See Fact Sheet. Treasury Details Efforts to Reduce Burden of Tax Regulations On October 4th, the Treasury Department announced that it has released a report on planned upcoming actions that it believes would reduce the burden of eight tax regulations identified earlier this year. Securities and Exchange Commission Guidance Investment Management Updates FAQs on Form ADV and IARD On September 29th, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management updated its frequently asked questions (“FAQs”) on Form ADV and the Investment Adviser Registration Depository (“IARD”) to reflect changes to Form ADV Part 1A that were implemented on October 1, 2017. Speeches and Statements House Committee Calls for Delay of CAT in the Wake of EDGAR Breach Disclosure In testimony before U.S. House of Representatives’ Financial Services Committee on October 4th, SEC Chairman Jay Clayton discussed the SEC’s initiatives, operations, and budget, and provided an update on developments in the SEC’s ongoing investigation of the 2016 breach of its EDGAR filing. The Wall Street Journal reported that Rep. Jeb Hensarling (R., Texas), the Committee’s chairman, pressed Clayton to delay implementation of the Consolidated Audit Trail (“CAT”) until the SEC has taken steps to secure its systems. Clayton Confirms that Personal Information of Two People Exposed during EDGAR Breach On October 2nd, SEC Chairman Jay Clayton updated his statement on the status of the SEC’s review and investigation of the 2016 breach of the EDGAR filing system. In addition to providing more information on the steps the SEC has taken to strengthen its cybersecurity profile, Clayton also disclosed that the staff’s investigation has found that the names, dates of birth, and social security numbers of two individuals were accessed by third parties as a result of the breach. Other Developments SEC to Consider Simplification of Regulation S-K Disclosures at Open Meeting The SEC will hold an Open Meeting on October 11, 2017, to consider whether to propose amendments to Regulation S-K to modernize and simplify certain disclosure requirements under the regulation as well as related rules and forms. SEC Meeting Notice. OIG Says SEC Still Has Challenges with Information Security and Meeting Oversight Responsibilities On October 5th, the SEC’s Office of Inspector General (“OIG”) released its annual statement on the most serious management and performance challenges faced by the SEC. The OIG identified several areas where the SEC faces management and performance challenges, including meeting regulatory oversight responsibilities; ensuring an effective information security program; improving contract management; and ensuring effective human capital management. Regulators Issue Joint Investor Bulletin for World Investor Week On October 2nd, the SEC’s Office of Investor Education and Advocacy, the Commodity Futures Trading Commission (“CFTC”), the Financial Industry Regulatory Authority (“FINRA”), and the North American Securities Administrators Association (“NASAA”) issued a joint Investor Bulletin to mark World Investor Week, a global campaign aimed at raising awareness about the importance of investor education and protection. The Bulletin highlights key investor education messages, including the importance of verifying the license status of investment professionals; understanding investment risk and the impact of fees; and diversifying investments. OIG Finds Deficiencies in SEC’s Data Center Management On September 29th, the OIG issued a report containing the findings of its audit of the SEC’s management of its data centers, which includes EDGAR and other telecommunications, data, and computing resources. The report found that the SEC’s failure to follow recommended data center relocation steps and its failure to adequately manage or monitor its data center contracts exposed SEC data to vulnerabilities. Section 31 Fee Rates Remain Unchanged at Start of Fiscal Year 2018 The SEC announced on September 29th that when fiscal year 2018 begins on October 1, 2017, the fees paid under Section 31 of the Securities Exchange Act will remain at the current rate of $23.10 per million for securities transactions, and the assessment on round turn transactions in security futures will remain at $0.0042 per transaction. The fees will remain at these rates until 60 days after the date of enactment of a regular appropriation for the SEC. OIG Completes Evaluation of SEC’s EDGAR Redesign On September 28th, the OIG published a report that details the results of its audit of the SEC’s progress in enhancing and redesigning the EDGAR system. Based on the findings, the OIG recommended, among other things, that the SEC clearly define the EDGAR system governance structure; improve EDGAR system scope management processes; and update the EDGAR change management policies. Federal Rules Effective Dates October 2017 – December 2017 Consumer Financial Protection Bureau October 19, 2017 Amendments to the 2013 Mortgage Rules Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z). 81 FR 72160. Amendments to the 2013 Mortgage Rules Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z); Correction. 82 FR 30947. October 1, 2017 Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z). 81 FR 83934. Amendments to Federal Mortgage Disclosure Requirements Under the Truth in Lending Act (Regulation Z). 82 FR 37656. Federal Deposit Insurance Corporation October 1, 2017 Recordkeeping Requirements for Qualified Financial Contracts. 82 FR 35584. Federal Financial Institutions Examination Council November 24, 2017 Collection and Transmission of Annual AMC Registry Fees. 82 FR 44493. October 2, 2017 Description of Office, Procedures, and Public Information. 82 FR 45697. Federal Reserve System November 13, 2017 Restrictions on Qualified Financial Contracts of Systemically Important U.S. Banking Organizations and the U.S. Operations of Systemically Important Foreign Banking Organizations; Revisions to the Definition of Qualifying Master Netting Agreement and Related Definitions. 82 FR 42882. November 1, 2017 Rules Regarding Availability of Information. 82 FR 45679. Treasury Department November 27, 2017 Changes to the In-Bond Process. 82 FR 45366. Exchanges and Self-Regulatory Organizations Financial Industry Regulatory Authority FINRA Implements New Charge for Review of Websites and Webpages in Native Format In a Regulatory Notice published on October 5th, FINRA announced that it has amended Section 13 of Schedule A to the FINRA By-Laws governing the review charge for communications filed with or submitted to FINRA’s Advertising Regulation Department. The amendment, effective immediately, establishes charges for a new option to submit websites and web pages in their native format in anticipation of the upcoming changes to the Advertising Regulation Electronic Files (“AREF”) System. SEC Approves Changes to FINRA’s Competency Exams On October 5th, FINRA announced that the SEC has approved its proposal to streamline competency exams by restructuring the representative-level qualification examinations to create a general knowledge examination called the Securities Industry Essentials (“SIE”) and transform the representative-level examinations into specialized knowledge examinations. The changes, which will become effective on October 1, 2018, also consolidate FINRA’s registration rules and amend the Continuing Education requirements. FINRA Regulatory Notice. SEC Approves FINRA’s Proposed Amendments to Definition of Non-Public Arbitrator FINRA announced in a Regulatory Notice published on October 4th that it has received approval from the SEC to amend its Customer and Industry Codes of Arbitration Procedure to provide that a non-public arbitrator is a person who is otherwise qualified to serve as an arbitrator, and is disqualified from service as a public arbitrator. The amendments will become effective on October 9, 2017. FINRA Extends Effective Date of Margin Requirements for Covered Agency Transactions In a Regulatory Notice published on September 29th, FINRA announced that it has extended the effective date of amendments to FINRA Rule 4210 establishing margin requirements for covered agency transactions. The amendments will now become effective on June 25, 2018. FINRA Board Considers Amendments to Rules Related to Remote Office Inspections and BrokerCheck Disclosure On September 29th, FINRA President and CEO Robert W. Cook provided an update regarding the discussions of FINRA’s Board of Governors at a recent meeting. Among other matters, the FINRA Board authorized publishing for comment proposed rulemaking items on the use of technology for remote office inspections and expanded access for investors to certain information on BrokerCheck; discussed potential changes to FINRA’s advisory committees; and considered the progress made on its FINRA 360 initiative. SEC Approves Extension of Pay-to-Play Rules to Capital Acquisition Brokers On September 29th, the SEC issued an order approving FINRA’s proposal to adopt Capital Acquisition Broker Rules 203 (Engaging in Distribution and Solicitation Activities with Government Entities) and 458 (Books and Records Requirements for Government Distribution and Solicitation Activities), which would apply established “pay-to-play” and related recordkeeping rules to the activities of member firms governed by the Capital Acquisition Broker (“CAB”) Rules and that engage in distribution or solicitation activities for compensation with government entities on behalf of investment advisers. SEC Release No. 34-81781. ICE Clear Credit SEC Approves Enhancements to ICC’s Liquidity Risk and Stress Testing Frameworks On October 2nd, the SEC approved a proposed rule change filed by ICE Clear Credit LLC (“ICC”) to make changes to the ICC Liquidity Risk Management Framework and the ICC Stress Testing Framework in an effort to enhance ICC’s stress testing and liquidity stress testing practices. SEC Release No. 34-81797. International Swaps and Derivatives Association ISDA Updates OTC Derivatives Compliance Calendar On October 2nd, the International Swaps and Derivatives Association (“ISDA”) released an updated version of its OTC Derivatives Compliance Calendar. LCH SA SEC Takes More Time to Consider LCH SA’s Proposal to Clear Options on Index Credit Default Swaps On October 4th, the SEC designated November 29, 2017, as the date by which it will approve, disapprove, or institute disapproval proceedings regarding LCH SA’s proposal to amend LCH SA’s CDS Clearing Rule Book, CDS Clearing Supplement, CDS Clearing Procedures, and CDS Dispute Resolution Protocol to incorporate relevant terms and make certain conforming and clarifying changes in order to permit LCH SA to clear options on index credit default swaps. SEC Release No. 34-81819. SEC Delays Action LCH SA’s Rule Changes Relating to Options on Index Credit Default Swaps On October 4th, the SEC designated November 19, 2017, as the date by which it will approve, disapprove, or institute disapproval proceedings concerning a proposed rule change filed by LCH SA to amend its CDS Margin Framework and CDS Clear Default Fund Methodology to incorporate terms and conforming changes, and to provide for risk management policies related to options on index credit default swaps in order to permit LCH SA to clear such options. SEC Release No. 34-81818. Municipal Securities Rulemaking Board MSRB Makes Available New Municipal Market Yield Curve on EMMA The Municipal Securities Rulemaking Board (“MSRB”) announced on October 5th that it has added a new municipal market yield curve to its Electronic Municipal Market Access (“EMMA”) website, which will assist investors in monitoring the level and direction of municipal bond interest rates and comparing relative yields of specific municipal securities. The new Bloomberg BVAL Municipal AAA Curve uses real-time trades and contributed sources to reflect market movement. MSRB Increases Professional Fee Rate for Municipal Advisors In a Regulatory Notice issued on September 29th, the MSRB announced that it plans to amend MSRB Rule A- 11, on assessments for municipal advisor professionals, to increase the annual municipal advisor professional fee from $300 to $500. The first payment under the new rate will be due on April 30, 2018. NASDAQ OMX Group SEC Approves Changes to Phlx’s Quarterly Trading Requirements for ROTs On October 5th, the SEC issued an order approving NASDAQ PHLX LLC’s (“Phlx”) proposal to amend the quarterly trading requirements applicable to Registered Options Traders (“ROTs”) by applying the requirement to trade 1,000 contracts and 300 transactions each quarter only to non-Streaming Quote Trader ROTs and adding a new alternative standard to meet this requirement. SEC Release No. 34-81826. Nasdaq Proposes Changes to Listing Requirements for Acquisition Companies On October 4th, the SEC provided notice of a proposed rule change filed by the NASDAQ Stock Market LLC (“Nasdaq”) to modify the listing requirements related to Acquisition Companies by reducing the number of round-lot holders required for initial listing on the Nasdaq Capital Market; eliminating the continued listing shareholder requirement; requiring that an Acquisition Company maintain at least $5 million in net tangible assets for initial and continued listing; and imposing a deadline for the company to demonstrate compliance with all initial listing requirements. Comments should be submitted within 21 days of publication in the Federal Register, which is expected the week of October 9, 2017. SEC Release No. 34-81816. Phlx Proposes to Modify Criteria for Listing an Option on an Underlying Covered Security On October 4th, the SEC requested comments on a proposed rule change filed by Phlx to amend its rules to permit the listing of an option on an underlying covered security that has a market price of at least $3.00 per share for the previous three consecutive business days preceding the date on which Phlx submits a certificate to the Options Clearing Corporation (“OCC”) for listing and trading. Comments should be submitted within 21 days of publication in the Federal Register, which is expected the week of October 9, 2017. SEC Release No. 34-81814. National Futures Association NFA Offers Instructions for SDs Submitting Swap Valuation Dispute Notices and Monthly Risk Data Reports On October 2nd, the National Futures Association (“NFA”) published a Notice to Members that provides additional filing instructions for swap dealers (“SD”) who must upload data as part of their submission of swap valuation dispute notices and monthly swap dealer risk data reports. The NFA also announced that it will hold a webinar on October 12, 2017, to provide additional information about these filing requirements. National Securities Clearing Corporation SEC Approves Changes to NSCC’s Fails Charge On September 29th, the SEC issued an order approving a proposed rule change filed by the National Securities Clearing Corporation (“NSCC”) that would amend an existing fails charge that applies to each NSCC member as part of each member’s required deposit to the NSCC Clearing Fund and clarify NSCC’s current practices with respect to the assessment and collection of the fails charge. SEC Release No. 34-81774. NYSE NYSE Offers Guidance on Market Access Rule Obligations In a Information Memo released on October 5th, the New York Stock Exchange LLC (“NYSE”) reminded members of their obligation to comply with all requirements of the SEC’s Market Access Rule, including the obligation to establish and maintain reasonable risk management controls and supervisory procedures, and to establish and monitor customer credit limits. The Bulletin highlights several issues for members to consider regarding the Market Access Rule and their obligations with respect to credit and capital limits. SEC Approves Changes to Complimentary Services Available to New Listings on NYSE American On September 29th, the SEC approved NYSE American LLC’s (“NYSE American”) proposal to amend provisions in its company guide on complimentary products or services available to eligible new listings to provide that companies initially listed on or after October 1, 2017, will not be eligible to receive corporate governance tools under NYSE American’s current services offering. SEC Release No. 34-81783. Industry News SEC Chair Puts Hold on Staff’s Plan to Approve Sale of Chicago Stock Exchange On September 28th, The Wall Street Journal reported on SEC Chairman Jay Clayton’s decision to freeze his staff’s plan to approve the sale of the Chicago Stock Exchange to a Chinese-led group. Clayton allegedly made this decision after consulting about the subject with the White House. Winston & Strawn Upcoming Events & Speaking Engagements Glen Barrentine Speaks at NSCP’s Annual Conference Partner Glen Barrentine will speak at the National Society of Compliance Professional’s National Conference in Washington D.C., held from October 15-18. Glen will co-host an Enforcement Issues panel on October 17, which will discuss current trends as well as priorities for regulators. Speaking Engagement. Simon Luk Speaks at CPD Fast Track Conference 2017 Simon Luk, partner and chairman of Winston & Strawn’s Asia Practice, will speak at LegalPlus’ Annual CPD Fast Track Conference on October 11, 2017. Simon will present “All You Need to Know About Private Equity in 2017,” which will provide the latest update to legal and finance professionals. Speaking Engagement. Winston & Strawn Publications Updates to Russia and North Korea Sanctions as the Countering America’s Adversaries Through Sanctions Act Is Implemented Recent developments have implemented and supplemented the sanctions against North Korea and Russia that were enacted over the summer in the Countering America’s Adversaries Through Sanctions Act on August 2, 2017 (the “Act”). Briefing. Antitrust and Competition – The EU Weekly Briefing, Vol 5, Issue 37 The EU Weekly Briefing is designed to provide timely updates on recent European Union competition law by including a short description of, and links to, recent developments. Newsletter. Contact Us For more information regarding the Financial Services Update and the Financial Services Practice please contact: Basil V. Godellas (+1 (312) 558-7237 or firstname.lastname@example.org) or Jay Gould (+1 (415) 591-1575 or email@example.com), Co-Chairs of Winston’s Financial Services Corporate Practice Group. 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