The financial services regulatory reform train has now pulled well out of the station, and Jorden Burt's Task Force has issued another in its series of Bulletins on this subject. The Bulletin, available here, discusses important ways in which certain of the most recent reform proposals affect some of Jorden Burt's core client groups.

For your convenience, we set forth below the outline of the Bulletin's contents:

I. INSURANCE

A. Regulation of Financial Companies that Present Systemic Risks

1. Tier 1 Financial Holding Company Designation

2. Prudential Regulation Standards

3. FDIC "Back-Up" Examination Authority

4. Regulatory Actions Against Functionally-Regulated Subsidiaries

5. Segregating Financial Activities into a New Intermediate Holding Company

6. Remedial Action

7. Disagreement over Federal Reserve Board Role

B. Financial Services Oversight Council

C. Office of National Insurance

1. Functions of ONI

2. International Agreements and Preemption of State Law

3. H.R. 2609-An Alternative Proposal

D. Federal "Resolution" Authority as to Financial Companies that Have Systemic Importance

1. Obama Administration Proposal

2. Implementing the Proposed Statutory Authority

3. Impact on Subsidiaries

E. Possible Regulation by Consumer Financial Protection Agency

II. INVESTMENT ADVISERS

A. Impact of Tier 1 Financial Holding Company Regulation

B. Impact of New Resolution Authority

C. Repeal of "15 Client" Exclusion

D. Additional Benefit of Being an SEC-Regulated Adviser

E. Possible Regulation by Consumer Financial Protection Agency

III. MONEY MARKET FUNDS

A. Background: September 18, 2009 Termination Date for Treasury Temporary Guarantee Program

B. SEC Proposals to Enhance Money Market Fund Resilience

C. Other Possibilities the SEC Has Raised for Money Market Funds

D. Next Steps

IV. HEDGE FUNDS AND OTHER PRIVATE FUNDS

A. Regulation Likely

B. Private Fund Investment Advisers Registration Act of 2009

1. Repeal of "15 Client" Exclusion

2. Providing Additional Information to Regulators

3. Repeal of Exemption for Intrastate Advisers and Commodity Trading Advisers

4. Potential Additional Disclosures to Investors, Counterparties, and Creditors

C. Other Pending Bills

D. European Union's Proposed Alternative Investment Funds Directive

V. PROPOSED CONSUMER FINANCIAL PROTECTION AGENCY

A. Potentially Comprehensive Nature of CFPA Regulation

B. The CFPA's Primary Areas of Concern

C. Relevance to Insurance Industry

D. Exclusion for Certain persons Regulated by the SEC or CFTC

F. Investment and Financial Advisory Activities

G. Certain Industry Communications with Congress

VI. OTHER LEGISLATIVE PROPOSALS

A. Investor Protection Act of 2009

B. Bank Holding Company and Depository Institution and Regulatory Improvements Act of 2009

C. Payment, Clearing, and Settlement Supervision Act of 2009

D. Consumer Protection and Regulatory Enhancement Act

The Bulletin, available here, is one of a continuing series of analyses being prepared by Jorden Burt's Task Force on Modernizing Financial Services Regulation.