The authors of a Swiss Institute Research paper found that trading volumes are larger and transaction costs are higher in the "dealer-to-client" trades than "interdealer trades" of the credit default swaps ("CDS") market. According to the finance professors Pierre Collin-Dufresne and Anders B. Trolle, et al., the CDS market has been functioning as a "two-tiered market" since the implementation of Dodd-Frank, consisting of client trades and interdealer trades. The difference in transaction costs, the authors determined, is due to (i) a "higher price impact of [client] trades" and (ii) the

The Financial Conduct Authority ("FCA"), the European Securities and Markets Authority ("ESMA") and other EU securities regulators agreed to two Memoranda of Understanding ("MoUs") regarding the activities of credit rating agencies, trade repositories and asset managers. These MoUs would be effective only if UK and EU authorities fail to reach an agreement over Brexit. The multilateral MoU with the FCA, the EU and European Economic Area ("EEA") National Competent Authorities (i) includes "supervisory cooperation, enforcement and information exchange" and (ii) allows the regulators to access

FDIC Chair Jelena McWilliams highlighted agency priorities to ensure that banks offer "affordable, responsible financial products and services to consumers across the spectrum." In remarks at the Florida Bankers Association Leadership Dinner, Ms. McWilliams stated that the agency's priorities include: encouraging de novo bank formation; she said that de novo banks are a "key source of new capital, talent, ideas, and ways to serve customers"; tailoring FDIC's regulations to permit banks to serve customers more efficiently while also making sure banks stay "safe and sound"; taking a "holistic"

In connection with the recent imposition of sanctions on Petróleos de Venezuela S.A. ("PdVSA"), the U.S. Treasury Department Office of Foreign Assets Control ("OFAC") issued two revised General Licenses and numerous new and revised Frequently Asked Questions ("FAQs"). The General Licenses and FAQs clarify the scope of activities that remain authorized with respect to PdVSA and its majority-owned subsidiaries, including Citgo Holdings, Inc. ("Citgo"). The revised General Licenses authorize certain dealings related to (i) specified bonds issued by entities owned by the Government of Venezuela (

The SEC Division of Corporation Finance (the "Division") granted to two exchange-traded funds exemptions ( see here and here) from Exchange Act rules prohibiting purchases outside of a tender offer. The relief is conditioned upon the following: "no purchases of subject securities or related securities made by broker-dealers acting as dealer-managers of a tender offer would be effected for the purpose of facilitating a tender offer"; any purchases of a portfolio security by a dealer-manager during a tender offer will be effected as "adjustments to a basket of securities in the ordinary course