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Article

Orrick, Herrington & Sutcliffe LLP | USA | 4 May 2012

Dodd-Frank Act implementation update

Title VII of the Dodd-Frank Act, titled the “Wall Street Transparency and Accountability Act of 2010” (“Title VII”), was enacted on July 21, 2010.

Article

Orrick, Herrington & Sutcliffe LLP | USA | 4 May 2012

Investment management industry challenges CPO registration requirement

On February 9th, the CFTC issued a final rule modifying its Rule 4.5 to require the advisers of an investment company registered under the Investment Company Act of 1940, such as a mutual fund or exchange-traded fund, to register as commodity pool operators if, generally, the fund invests a material amount of its assets in speculative commodity futures, options and swaps.

Article

Orrick, Herrington & Sutcliffe LLP | USA | 15 Feb 2012

Dodd-Frank Act implementation update

Title VII of the Dodd-Frank financial reform, titled the “Wall Street Transparency and Accountability Act of 2010” (“Title VII”), was enacted on July 21, 2010.

Article

Orrick, Herrington & Sutcliffe LLP | USA | 15 Feb 2012

CFTC issues final rule on CPOCTA registration and compliance regulations

On February 9th, the CFTC approved certain rule changes intended to increase transparency to the CFTC of commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) active in the futures and swaps markets.

Article

Orrick, Herrington & Sutcliffe LLP | USA | 9 Aug 2011

Dodd-Frank Act implementation update

Title VII of the Dodd-Frank financial reform, titled the “Wall Street Transparency and Accountability Act of 2010” (the “Dodd-Frank Act”), was enacted on July 21, 2010.

Article

Orrick, Herrington & Sutcliffe LLP | USA | 26 May 2011

OCC proposes rule for retail foreign exchange transactions

On April 22nd, the Office of the Comptroller of the Currency (the “OCC”) proposed a rule (the “Proposed OCC FX Rule”) authorizing national banks to engage in offexchange transactions in foreign currency with retail customers, subject to certain specified conditions

Article

Orrick, Herrington & Sutcliffe LLP | USA | 26 May 2011

Dodd-Frank implementation update

Title VII of the Dodd-Frank Act,1 titled the “Wall Street Transparency and Accountability Act of 2010” (the “Act”), was enacted on July 21, 2010.

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