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SEC Proposes Significant New Regulatory Obligations for Communication Protocol Systems and Government Securities ATSs

The Securities and Exchange Commission (SEC) proposed significant changes to the regulation of securities trading systems that use non-firm trading interest and alternative trading systems (ATSs) that trade government...more

The SEC Issues Statement and Requests Comment Regarding the Custody of Digital Asset Securities by Special Purpose Broker-Dealers

On December 23, 2020, the Securities and Exchange Commission (SEC or Commission) issued a statement (Statement) regarding the custody of digital assets that are “securities” under the federal securities laws. The Statement...more

Navigating the "Good Faith Effort" Standard for Reg BI and Form CRS Implementation

Firms must demonstrate a “good faith effort” to comply. Last month, SEC Chairman Clayton issued a public statement communicating that firms should not expect a delay of the June 30, 2020 compliance date for Regulation Best...more

No Relief on Reg BI and Form CRS: Firms Must Comply by June 30th, Although Examiners Will Apply a “Good Faith Effort” Standard

On April 2, SEC Chairman Clayton issued a public statement concerning the SEC’s implementation of Regulation Best Interest (“Reg BI”) and Form CRS, available here. The bottom line: firms should not expect a delay in the Reg...more

The SEC Adopts Security-Based Swap Rules Governing Risk Mitigation Techniques for Uncleared Security-Based Swaps

On December 18, 2019, the Securities and Exchange Commission (the SEC or Commission) adopted new rules pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) requiring the...more

The SEC's Security-Based Swap Recordkeeping and Reporting Rules

On September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major...more

The SEC Adopts Security-Based Swap Rules Governing Capital, Margin and Segregation

On June 21, 2019, the Securities and Exchange Commission (SEC or Commission) adopted a package of rules and rule amendments (Rules) that set forth the capital, margin and segregation requirements for security-based swap...more

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