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Pepper Hamilton LLP | USA | 5 Jun 2018

Federal Reserve Proposes Rulemaking to Simplify the Volcker Rule

The Federal Reserve Board (FRB) has taken the first step toward providing banks meaningful relief from the Volcker Rule by soliciting public comment


Pepper Hamilton LLP | USA | 18 Oct 2017

CFTC Extends Its Reach to Potentially Include Initial Coin Offerings

The Commodity Futures Trading Commission (CFTC) has now made it clear that, in its view, certain initial coin offerings (ICOs) within the


Pepper Hamilton LLP | USA | 15 Feb 2017

Update: CFTC Delays Compliance Deadline for New Swap Margin Rules

Financial Services Client Alert Although the letter technically does not delay the effective date of March 1, 2017, from the perspective of the buy


Pepper Hamilton LLP | USA | 27 Jan 2017

Regulatory discussion- Investment Management Roundtable Series

Pepper partner Gregory J. Nowak hosted an Investment Management Update webinar for West LegalEdcenter. For this episode, Mr. Nowak is joined by Pepper


Pepper Hamilton LLP | USA | 17 Sep 2014

CFTC grants exemptive relief to private fund managers: general solicitation conditionally permitted

The JOBS Act and the regulations thereunder (which went effective on September 23, 2013) applies to private issuers - including hedge funds and


Pepper Hamilton LLP | USA | 2 Jul 2014

Observation 1.0.1 on the Volcker Rule: with summer comes the first wave of guidance

As we predicted in Observation 1.0, the inevitable waves of Volcker Rule guidance and interpretation have begun. A set of frequently asked questions


Pepper Hamilton LLP | USA | 19 Dec 2012

CFTC gives the swaps market an early Christmas present

In a notice released December 18, 2012, the Commodity Futures Trading Commission (CFTC) delayed the effective date of certain implementation rules for participants in the swaps markets.


Pepper Hamilton LLP | USA | 13 Dec 2012

U.S. district court rebuffs ICI challenge to CFTC Rule 4.5 amendments

On December 12, 2012, the U.S. District Court for the District of Columbia released its decision in Investment Company Institute v. U.S. Commodity Futures Trading Commission, rebuffing the Investment Company Institute (ICI)’s and U.S. Chamber of Commerce (Chamber)’s efforts to overturn recently adopted Commodity Futures Trading Commission (CFTC) amendments to CFTC Rules 4.5 (exclusion from definition of commodity pool operator) (CPO) and 4.27 (CPO and CTA reporting requirements) (the Amended Rules).


Pepper Hamilton LLP | USA | 8 Nov 2011

SEC and CFTC working on regulatory harmonization

The Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) required that the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly issue rules establishing the form and content of reports to be filed by private funds.


Pepper Hamilton LLP | USA | 18 Aug 2011

Dodd-Frank regulators beware: new rules will not survive without sound economic justification

In late July, the Court of Appeals for the District of Columbia (D.C. Circuit) handed the Securities and Exchange Commission (SEC) a scathing rebuke, after reviewing the agency’s first Dodd-Frank Act (DFA) regulation, a rule that would have required publicly traded companies to include in proxy materials potentially voluminous information on director candidates nominated by shareholders rather than by the board of directors.

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