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Crypto Exchange-Traded Products: Navigating the Intersection of Crypto and Securities

Direct ownership of crypto-assets or mere exposure to the value of crypto-assets is an investment decision, with both investment methods requiring specific approaches to mitigate and manage risks effectively....more

Stablecoins: Revolutionizing Global Finance?

Following the recent focus on two major regulatory frameworks—the Guiding and Establishing National Innovation for U.S. Stablecoins Act (known as the GENIUS Act) in the United States, and Regulation (EU) 2023/1114 of the...more

U.S. House Passes GENIUS and CLARITY Acts, Signaling Bipartisan Support for Digital Assets

The GENIUS Act's passage marks the first major crypto legislation approved by both chambers of Congress, signaling a significant step toward regulatory clarity for stablecoins, while the CLARITY Act's advancement by the House...more

The CFTC Proposes Rules to Protect Clearing Member Funds Held by DCOs

In Short - The Situation: In a December 13, 2023, Open Meeting, the Commodity Futures Trading Commission proposed amendments to the Commission's regulations concerning clearing member funds held by a derivatives clearing...more

The CFTC Proposes "Guidance" for Derivatives Markets on Listing Voluntary Carbon Credit Derivatives

In Short - The Background: As voluntary carbon credits ("VCCs") have grown in popularity, questions about their integrity and quality have arisen for investors and among regulators and lawmakers. For this reason, many have...more

CFTC Lacks Jurisdiction Over TRS on ETFs and Custom Baskets

In Short - The Situation: The civil action of the Commodity Futures Trading Commission ("CFTC") against Archegos Capital Management LP and its CFO is but one of many civil and criminal matters arising out of Archegos's...more

ESG Risks for Financial Institutions Operating in the United States: What to Expect in 2022

ESG considerations will continue to play an ever-increasing role in financial markets in 2022. ESG-related transactions will continue to present significant opportunities for financial institutions as they respond to and...more

Biden's Executive Order on Climate-Related Financial Risk: What's Next for Financial Institutions?

President Biden issued an Executive Order asking the Secretary of the U.S. Department of the Treasury to work with the Financial Stability Oversight Council to assess risks that climate change poses to the financial system....more

Litigation and Regulatory Considerations and Risks for Financial Market Participants in a Post-Pandemic Society

More than a year ago the world fell victim to a global pandemic that would change life in ways that could never have been predicted. In the early stages of the pandemic, we published a White Paper directed at financial...more

ISDA Publishes REC Annex

The International Swaps and Derivatives Association (ISDA) is launching and publishing the ISDA U.S. Renewable Energy Certificate Annex (REC Annex) to enable market participants to efficiently sell and purchase renewable...more

What the Financial Services Industry Can Expect From State Attorneys General in a Biden Administration

State attorneys general have become significant players in the financial world, using a number of special investigative and enforcement tools to investigate and prosecute alleged wrongdoing by financial market participants....more

ESG Risks for Financial Institutions: Eliminating Significant "Gotchas"

The Background: Demand for environmental, social, and governance ("ESG")-aligned companies and investment products is transforming the investing landscape. Financial institutions will be at the forefront of this change, as...more

New York's Highest Court Upholds Minority Noteholders' Rights Under Trust Indenture Act

The Situation: In a sharply divided 4-3 decision, CNH Diversified Opportunities Master Account, L.P., et al. v. Cleveland Unlimited, Inc. et al., Case No. 42 (Oct. 22, 2020), the New York Court of Appeals reversed the courts...more

Decision Time for the ISDA 2019 Narrowly Tailored Credit Events Protocol

The Situation: The International Swaps and Derivatives Associations, Inc. ("ISDA") is in the process of amending its credit derivatives documentation to address concerns market participants and regulators have raised...more

ISDA’s CDS Consultation: A Potential Fix for Narrowly Tailored Credit Events

The Situation: The International Swaps and Derivatives Association ("ISDA") has published proposed changes to the 2014 Credit Derivatives Definitions ("Definitions") that are meant to address issues relating to narrowly...more

Second Circuit Concludes Commodity Exchange Act Claims Accrue When Plaintiffs Learn Of Their Injuries

Under the "discovery accrual rule" discovery of the injury starts the clock for statute of limitations purposes. On February 28, 2019, the Second Circuit issued an important decision regarding the statute of limitations...more

Windstream: When a Credit Derivatives Determinations Committee and a Court Disagree

The Situation: Following a recent court decision holding that Windstream Services, LLC ("Windstream") failed to pay hundreds of millions of dollars in accelerated debt in 2017, the Credit Derivatives Determinations Committee...more

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