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REVERSEinquiries Newsletter, Volume 6, Issue 1 - July 1 2025

An Overview of Which Market Disruption Events to Include for the Most Common Asset Classes under a Medium-Term Note Program - A movie scene showing a day in the life of a calculation agent would likely not survive the...more

US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform

Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more

SEC Issues Concept Release on Definition of Foreign Private Issuer

On June 4, 2025, the U.S. Securities and Exchange Commission (the “Commission” or “SEC”) issued a concept release soliciting public comment on the definition of foreign private issuer (“FPI”), particularly on whether the...more

SEC Small Business Advisory Committee to Consider the Market Impact and Challenges of Regulation A

The Securities and Exchange Commission’s (SEC) Small Business Capital Formation Advisory Committee (the “Committee”) will meet on May 6, 2025 to consider the market impact and challenges associated with Regulation A....more

Convertible Bonds: An Issuer’s Guide (2025)

Introduction - Convertible bonds are, customarily, fixed rate debt instruments issued by a company (the “issuer”), the terms of which allow the holders of the bonds to convert them into ordinary shares (common stock) of...more

Treasury Markets Trading and Clearing

Acting SEC Chair Uyeda spoke at the Institute of International Bankers’ (IIB) Annual Washington DC Conference on March 11, 2025, about the U.S. Treasury markets. Acting Chair Uyeda discussed the regulation of exchanges....more

SEC Expands Accommodations for Issuers Submitting Draft Registration Statements

On March 3, 2025, the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) announced a new policy, with immediate effect, expanding the accommodations available for issuers that...more

Additional SEC Staff Accommodations for Confidential Submissions of Registration Statements

Yesterday, the Staff of the Division of Corporation Finance of the Securities and Exchange Commission announced a new policy permitting confidential submission of registration statements in additional circumstances in order...more

SEC Extends Compliance Dates and Provides Temporary Exemption for Rule Related to Clearing of U.S. Treasury Securities

On February 25, 2025, the SEC extended the compliance dates for Rule 17ad-22(e)(18)(iv)(A) and (B) under the Securities Exchange Act for eligible cash market transactions by one year to December 31, 2026, and for eligible...more

SEC to Review Clearing Rule Compliance for U.S. Treasury Securities Amid Industry Concerns

The SEC is set to hold an open meeting on February 26, 2025, to discuss extending compliance deadlines and granting temporary exemptions for covered clearing agencies (CCAs) handling U.S. Treasury securities. This review...more

SEC Drops Appeal of “Dealer Rule” Litigation

On February 19, 2025, the Securities and Exchange Commission (the “Commission” or “SEC”) dropped its appeal of a ruling by the U.S. District Court for the Northern District of Texas (“District Court”) on November 6, 2024 that...more

Sustainable Commercial Paper: Short-Term Paper, Long-Term Impact

Over the past few years, we have seen growing interest in Commercial Paper (CP) programmes with a sustainable focus. Traditionally used by corporations, financial institutions, sovereigns, and other issuers for...more

FINRA Will Not Set an Effective Date for Amendments to TRACE Rules Establishing One-Minute Reporting Requirement; FINRA to Prepare...

On February 5, 2025, Robert Cook, President and Chief Executive Officer of the Financial Industry Regulatory Industry, Inc. (“FINRA”), announced that FINRA will not set an effective date for its recent amendments (the...more

Fintech Funding Trends 2024: Capital Raising Slows, Deal Sizes Grow

According to CB Insights’ State of Fintech 2024 Report (the “Report”), global fintech companies raised $33.7 billion in private placements in 2024, marking a 20% drop year-over-year.  Deal volume also declined, with 3,580...more

What’s the Deal? – Rule 10b5-1 Plans

Here’s the deal: A Rule 10b5‐1 plan is a written securities trading plan that is designed to comply with Rule 10b5‐1(c) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”)....more

Market Outlook for IPOs in 2025: Insights from PLI’s 56th Annual Institute on Securities Regulation

On November 14, 2024, the Practising Law Institute’s 56th Annual Institute on Securities Regulation featured a panel discussion that provided valuable insights into the initial public offering (IPO) landscape for 2025....more

SEC Testifies Before Congress & Updates from the Division of Corporation Finance

The Chair and Commissioners of the Securities and Exchange Commission testified before the US House of Representatives Committee on Financial Services on September 24, 2024.  The SEC’s testimony provided updates on market...more

SIFMA Fact Book—Capital Markets Activity

Last week, SIFMA released its annual Capital Markets Fact Book, which reports comprehensive data on capital markets activity generally.  The U.S. equity markets represent 42.6% of the $115 trillion global equity markets, with...more

The Pendulum Swings Back: FDIC Proposes Changes to Brokered Deposits Restrictions

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s...more

Report: Reforms to Restore Confidence in the SEC

A number of trade associations (The Business Roundtable, the American Investment Council, The Center for Capital Markets Competitiveness of the US Chamber of Commerce, the Investment Company Institute, the Managed Funds...more

Investment Research

During his remarks at a meeting of the International Bar Association’s Asset Management Industry Conference on Global Challenges and Opportunities in Boston, Commissioner Uyeda commented on investment research and the...more

Chair Gensler Testimony Before House Subcommittee

Chair Gensler recently testified before the Subcommittee on Financial Services and General Government in connection with the Securities and Exchange Commission budget request.  In his testimony, the Chair included a number of...more

FINRA Announces Effective Dates for Remote Inspections Pilot Program & Residential Supervisory Location Rules; COVID-19 Relief...

The Financial Industry Regulatory Authority, Inc. (“FINRA”) announced via Regulatory Notice 24-02 (the “Notice”) the effective dates and other important timeframes for new FINRA Rules 3110.18 (Remote Inspections Pilot...more

Treat Like as Like? SEC Adopts Final Rules for SPAC IPOs and de-SPAC Transactions

As we previously posted, the Securities and Exchange Commission held an open meeting this morning to consider and vote on whether to adopt final rules regarding SPAC IPOs and business combinations (de-SPAC transactions). ...more

Ripple is Not a Tidal Wave – the SEC’s Case Against Terraform Labs Provides a Quick Counterpoint to the Recent Ripple Ruling

Just weeks after the novel securities analysis in SEC v. Ripple Labs was handed down by Judge Analisa Torres, a different judge in the Southern District of New York has distinguished the approach taken in Ripple and argued...more

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