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Earlier this month, SEC Chairman Jay Clayton issued a statement announcing a change in the SEC’s waiver application process that will streamline the SEC settlement process. The Commissi...
The Federal Reserve, OCC, FDIC, SEC and CFTC adopted final amendments on July 9, 2019 implementing the small-bank exclusion and name-sharing provisions of the Economic Growth, Regulatory ...
Davis Polk submitted a comment letter to the Board of Governors of the Federal Reserve System (Federal Reserve) on its notice of proposed rulemaking (the Board Proposal) to amend its regu...
The U.S. banking agencies have released a final rule amending the U.S. Basel III capital rules to simplify the capital treatment of capital deductions and recognition of minority interest...
Broker-dealer custody of on-blockchain assets has been a key hurdle in the development of a more regulated financial infrastructure for digital assets in the United States. In a joint sta...
On June 21, 2019, the SEC adopted security-based swap (SBS) capital, margin and segregation requirements (the SEC Rules) for SBS dealers (SBSDs) and major SBS participants, revised the ca...
In a typical “term loan B” (TLB) financing, the initial lenders expect to distribute the TLB paper to investors prior to funding. But what happens when that expectation cannot be met,...
The Treasury Department and IRS in April released a second set of proposed regulations governing tax incentives for investment in “qualified opportunity zones.” We expect the new rule...
The main lesson from the CFPB symposium on “abusive acts or practices” is that there won’t be any clarity anytime soon. In response to long-lasting concerns from the financial serv...
The Supreme Court in Kisor v. Wilkie has declined to overrule Auer v. Robbins and Bowles v. Seminole Rock & Sand Co., instead narrowing deference to a federal agency’s interpretation of...