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Steven Lofchie Commentary by Steven Lofchie

The SEC approved a proposed rule change to FINRA Rule 0150 ("Application of Rules to Exempted Securities Except Municipal Securities") that applies to FINRA Rule 2121 ("Fair Prices and Commissions") and its Supplementary Material .01 ("Mark-up Policy") and .02 ("Additional Mark-up Policy for Transactions in Debt Securities, Except Municipal Securities") to transactions in exempted securities that are government securities. The SEC's rule change approval was published in the Federal Register.

The Committee on Payments and Market Infrastructures ("CPMI") and the International Organization of Securities Commissions ("IOSCO") requested comments on the proposed approach to the Unique Product Identifier ("UPI"). The purpose of the global UPI is to create a unique identifier for over-the-counter derivatives products that are subject to reporting requirements to trade repositories. This report outlines CPMI-IOSCO's proposed product classification principles and high-level business specifications for the UPI and requests respondents' feedback on them, in particular with regard to

Steven Lofchie Commentary by Steven Lofchie

The Basel Committee on Banking Supervision proposed a conceptual framework with the objective of mitigating "spillover effects" from the shadow banking system to banks. For the purposes of the consultative document, step-in risk refers to the risk that a bank will provide financial support to an entity beyond or in the absence of its contractual obligations, should the entity experience financial stress. The proposals would form the basis of an approach for identifying, assessing and addressing step-in risk potentially embedded in banks' relationships with shadow banking entities. According to

Steven Lofchie Commentary by Steven Lofchie

The SEC Divisions of Corporation Finance and Economic and Risk Analysis analyzed various approaches for modifying the definition of an "accredited investor." Under the Dodd-Frank Act, the SEC must review this definition as it applies to natural persons every four years. The Divisions' recommendations for methods to revise the definition included: The SEC should revise the financial thresholds requirements and the list-based approach for entities as follows: leave the current income and net worth thresholds in place, subject to investment limitations; add new inflation-adjusted income and net

Commentary by Nihal Patel

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") reminded swap dealers ("SDs") and major swap participants ("MSPs") to comply with data reporting obligations under CFTC Rules 23.204 ("Reports to Swap Data Repositories") and 23.205 ("Real-Time Public Reporting"). The staff noted that the advisory comes as staff has observed that SDs and MSPs "are having reporting issues and failures" resulting in inaccurate and untimely swap data reporting. The DSIO noted the following frequent reporting issues and failures by SDs and MSPs: (i) readily apparent errors; (ii) incomplete