LawFlash/Client Alert | Investment Management LawFlash
Michael Piracci, F. Mindy Lo, Laura Flores
Investment advisers operating registered investment companies and private funds that conduct more than a de minimis amount of speculative trading in futures, commodity options, and other commodity interests will no longer be exempt from registering with the CFTC as CPOs.
LawFlash/Client Alert | Investment Management LawFlash
Michael Piracci, F. Mindy Lo, Laura Flores
CFTC requests comments on proposed rules intended to harmonize certain CFTC and SEC disclosure, reporting, and recordkeeping requirements in an effort to mitigate the burden on registered investment companies required to comply with the two separate compliance regimes.
LawFlash/Client Alert | Investment Management LawFlash
John O'Brien, Monica Parry, Ethan Johnson
On October 26 and October 31, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC), respectively, approved rules that will require certain investment advisers to report extensive info... more
LawFlash/Client Alert | Investment Management and Restructuring LawFlash
Joshua Blackman, Robert Mendelson
On October 31, the Securities Investor Protection Corporation (SIPC) filed for a protective order under the Securities Investor Protection Act (SIPA) for MF Global Inc., a company registered jointly as an Securities and Exchange... more
LawFlash/Client Alert | Investment Management LawFlash
John O'Brien, Ethan Johnson
On October 11 and 12, several federal agencies jointly released proposed rules that would implement the so-called "Volcker Rule."[1] The Volcker Rule, which prohibits "banking entities" from... more
Presentation | Speech
Ben Indek
LawFlash/Client Alert | Energy LawFlash
Mark Haskell, Fred Fielding, Levi McAllister
On October 18, the Commodity Futures Trading Commission (CFTC) issued a Final Rule codifying regulations that establish limits on speculative positions in 28 physical commodity futures contracts traded pursuant to the rules of a... more
LawFlash/Client Alert | Investment Management LawFlash
Investment Management Practice
On October 11, the Financial Stability Oversight Council (the Council) released a second notice of proposed rulemaking and proposed interpretive guidance for determining whether a nonbank financial company would be subject to th... more
Outside Publication | Article
R. Dawson, Sheryl Orr
Presentation | Speech
Andrew Donohue, John O'Brien, P. Georgia Bullitt, Christian Mixter, Timothy Levin, Joseph Floren, W. John McGuire, Thomas Harman, David Sirignano, Michael Piracci
Presentation | Speech
Mark Haskell
LawFlash/Client Alert | Investment Management LawFlash
Michael Piracci, P. Georgia Bullitt, F. Mindy Lo
As things currently stand, on July 16, when the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act)[1] becomes effective, Securities and Exchange Commission (SE... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued Notice 2011-1 (the Notice) on May 31, providing a filing extension until June 30, 2012 for certain U.S. persons with signature authority ov... more
Presentation | Speech
Ben Indek
LawFlash/Client Alert | Energy LawFlash
Stephen Spina, Mark Haskell, George Billinson, John McGrane
On April 21, 2011, the Federal Energy Regulatory Commission (FERC) issued an Order Affirming Initial Decision and Ordering Payment of Civil Penalty in connection with an Administrative Law Judge's (ALJ) Initial Decision that a n... more
Presentation | Speech
Andrew Donohue, P. Georgia Bullitt, W. John McGuire, John O'Brien
LawFlash/Client Alert | Tax LawFlash
Tax Practice
The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued final regulations (RIN 1506-AB08) on February 24 regarding the requirements for certain U.S. persons to file Form TD F 90-22.1, Report of F... more
Outside Publication | Article
William Zimmerman
LawFlash/Client Alert | Investment Management LawFlash
Michael Piracci
In a sign of its increased regulatory muscle, on January 26 the Commodity Futures Trading Commission (CFTC) issued proposed rules regarding commodity pool operators (CPOs) that not only proposed eliminating the CFTC Rule 4.5 exe... more
LawFlash/Client Alert | Investment Management LawFlash
Investment Management Practice
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) issued rule proposals requiring investment advisers to private funds, which are not regulated by these two agencies, to provide det... more
LawFlash/Client Alert | Financial Regulatory Reform LawFlash
Thomas D'Ambrosio
CFTC and SEC solicit comments on proposed rules governing the commercial end-user exemption to the clearing requirements of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Morgan Lewis Title | White Paper
Michael Kraut, Anne Flannery, Ben Indek, Christian Mixter, Kerry Land, David Snider, Mary Dunbar, Kevin Rover, E. Andrew Southerling, Julia Miller
This Outline highlights selected U.S. Securities and Exchange Commission (the "SEC" or the "Commission"), Financial Industry Regulatory Authority ("FINRA") and NYSE Euronext enforcement actions and developments regarding broker-... more
Outside Publication | Article
Joseph Yanoshik, Monica Parry, Jennifer Klass
Outside Publication | Article
Beth Kiesewetter, Christopher Menconi
LawFlash/Client Alert | Investment Management LawFlash
Michael Piracci, Ethan Johnson, P. Georgia Bullitt, W. John McGuire, Laura Flores, Rebecca Leon
On September 17, the Commodity Futures Trading Commission (CFTC) published in the Federal Register a request for comments on National Futures Association's (NFA's) petition for rulemaking (the Petition), to revise the exclusions... more