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SEC Release 34-64017 March 3, 2011 The SEC published for comment a proposal under Dodd-Frank regarding registration of clearing agencies and the operation and governance of clearing agencies. Among other things, the proposed rules would require clearing agencies to (i) maintain risk management standards; (ii) have safeguards for protecting confidential information; (iii) identify and address conflicts of interest; (iv) designate a chief compliance officer; and (v) disseminate pricing and valuation information if they perform central counterparty services for security-based swaps. In addition

SEC Release No. 33-9199, 34-64149 March 30, 2011 The SEC proposed new rules to implement Exchange Act Section 10C (as added by Section 952 of Dodd-Frank). The new rules would direct national securities exchanges and associations to prohibit the listing of equity securities of issuers that are not in compliance with Section 10C 's standards for compensation committees and compensation advisers. Comments on the proposal are due by April 29, 2011. Cross References SEC Press Release 2011-78 Exchange Act § 10C Dodd-Frank § 952 Statements of SEC Commissioners: Schapiro , Casey , Paredes , Aguilar

International Swaps and Derivatives Association April 29, 2011 ISDA submitted comments on the SEC notice of proposed rulemaking Clearing Agency Standards for Operation and Governance addressing clearing member eligibility, default procedures, margin requirements, and settlement requirements. Cross References Dodd-Frank Section 763; Dodd-Frank Section 805; Securities Exchange Act Section 17A

On June 20, 2012, the SEC adopted a new rule and amendments to its proxy disclosure rules to implement Section 952 of the Dodd-Frank Act, which added Section 10C to the Exchange Act. Section 10C requires the SEC to adopt new disclosure rules concerning compensation consultant conflicts of interest. Section 10C also requires the SEC to adopt rules directing the national securities exchanges-such as NYSE and NASDAQ-and national securities associations (collectively, the "exchanges") to adopt listing standards with respect to compensation committees and compensation advisers. Under the new rule