News & Analysis as of

Dodd-Frank Wall Street Reform and Consumer Protection Act No-Action Letters

The Dodd-Frank Wall Street Reform and Consumer Protection Act is a United States federal statute signed into law on July 21, 2010. The Act was passed in response to the Great Recession of the late 2000s and... more +
The Dodd-Frank Wall Street Reform and Consumer Protection Act is a United States federal statute signed into law on July 21, 2010. The Act was passed in response to the Great Recession of the late 2000s and includes broad reforms related to many aspects of the financial and banking industry. Notable sections of the Act include stricter regulations of the derivatives market, as well as the Volcker Rule, which restricts the trading practices of FDIC-insured institutions.    less -
Katten Muchin Rosenman LLP

CFTC Staff Issues Relief Intended to Reduce Burdens of Swap Data Notification Requirements

Staff from the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued No-Action Relief Letter 25-25 on July 31, 2025 to help ease compliance burdens placed on reporting counterparties in meeting the...more

Eversheds Sutherland (US) LLP

CFTC issues no-action letter regarding CME’s listing of event contracts

On July 22, 2025, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk issued a no-action letter (CFTC Letter No. 25-23) granting targeted regulatory relief to the...more

Katten Muchin Rosenman LLP

CFTC Issues No-Action Relief for SEFs on Order Book Obligations

In a marked departure from its position since 2013, the Commodity Futures Trading Commission (CFTC) issued No-Action Letter 25-24 on July 30, 2025 (Letter 25-24), stating that it will not recommend enforcement action against...more

Patomak Global Partners

CFTC Eases SDR Error Notification Requirements With New No-Action Relief

Reporting counterparties must correct any error in their SDR reporting “as soon as technologically practicable” and, “[i]n all cases, […] within seven business days” after its discovery. If they fail to do so, they must...more

Mayer Brown

Everyone’s Human: CFTC Rationalizes Swap Error Reporting

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On July 31, 2025, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for certain swap reporting counterparties that fail to submit a swap data error correction notification (“NAL 25-25”). This relief...more

Hogan Lovells

SEC grants no action relief from paragraph (a)(3)(iii) of Rule 192

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The Securities and Exchange Commission has issued a no-action relief letter regarding paragraph (a)(3)(iii) of Rule 192 under the Securities Act of 1933, as amended. Rule 192, finalized in January 2024, implements Section 621...more

Morgan Lewis

SEC Staff Greenlights Information Barriers as Alternative Approach to Rule 192 Compliance

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The staff of the US Securities and Exchange Commission’s Division of Corporation Finance recently granted no-action relief for transactions under Securities Act Rule 192(a)(3)(iii) (commonly known as prong (iii)) where the...more

Cadwalader, Wickersham & Taft LLP

Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures

On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called...more

Husch Blackwell LLP

CFPB Reboots Policy Statements for No-Action Letters and Compliance Assistance Sandbox Approvals Days Before Administration Change

Husch Blackwell LLP on

On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more

Wiley Rein LLP

Wiley Consumer Protection Download (November 9, 2020)

Wiley Rein LLP on

Regulatory Announcements - CFPB Issues No Action Letter to Facilitate Consumer Access to Loans. The Consumer Financial Protection Bureau (CFPB) issued a No-Action Letter to Bank of America, N.A. on November 5 regarding...more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

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In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Illusory Promise or Real Change? Transition at CFTC Brings Hope for Dodd-Frank Act Revisions

Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more

Morgan Lewis

CFPB Revises Trial Disclosure Policy and Issues Compliance Assistance Sandbox Policy

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In addition to releasing a finalized No-Action Letter (NAL) Policy, the Consumer Financial Protection Bureau (CFPB) also issued a revised Trial Disclosure Policy and Compliance Assistance Sandbox Policy on September 10....more

Nutter McClennen & Fish LLP

Fintech in Brief: Issues to Consider in Connection with the CFPB’s Proposed Product Sandbox and Policy Changes for No-Action...

Bank, nonbank, and Fintech providers of consumer financial products and services may be able to reduce their exposure to compliance risk under the December 13, 2018 No Action Letter (“NAL”) Policy changes proposed by the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent SEC No-Action, Re-Proposal for Security-Based Swaps Focus on Comparability With Other US Regulators

In recent days, the Securities and Exchange Commission (SEC) announced a no-action position on enforcing its 2016 Business Conduct Standards against security-based swap dealers (SBSDs) and major security-based swap...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

Polsinelli on

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more

Snell & Wilmer

Corporate Communicator - 2017 Annual Meeting Season

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Dear clients and friends, We present our traditional year-end issue of Snell & Wilmer’s Corporate Communicator to help you prepare for the upcoming annual report and proxy season. This issue highlights SEC reporting and...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more

Goodwin

Financial Services Weekly News - June 2016 #4

Goodwin on

Regulatory Developments - SEC Issues Order Approving Inflation Adjustments to “Qualified Client” Dollar Thresholds for Investment Adviser Performance Fee Rule - On June 14, the SEC issued an order approving...more

Goodwin

CFPB Steps Up Scrutiny of FinTech Companies

Goodwin on

On March 7, 2016, the Consumer Financial Protection Bureau (CFPB) announced that it will begin collecting complaints from consumers about online marketplace lenders, signaling its intention to increasingly regulate the...more

Ballard Spahr LLP

Director Cordray defends CFPB positions in appearance before Senate Banking Committee; comments on small business lending and...

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Much of Director Cordray’s testimony in his appearance before the Senate Banking Committee yesterday consisted of his predictable defense of various CFPB positions. While the hearing was much less contentious than last...more

Katten Muchin Rosenman LLP

CFPB Issues Final Policy on No-Action Letters

The Consumer Financial Protection Bureau (Bureau) issued its final policy on its issuance of no-action letters on February 18, which is intended to further objectives under section 1021 of the Dodd-Frank Wall Street Reform...more

Alston & Bird

Financial Services & Products Advisory: CFTC Provides Swap Clearing Relief for Smaller Bank Holding Companies and Savings and Loan...

Alston & Bird on

On January 8, 2016, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Clearing and Risk (DCR) issued a no-action letter (CFTC Letter 16-01) providing relief from the clearing requirement for some swaps...more

Adler Pollock & Sheehan P.C.

Glossary of Important Securities Regulation Terms and Definitions

This Glossary is designed to provide law students taking Securities Regulation with a tool that will assist them in learning the basic language of securities law and achieve a working knowledge of the fundamental principles...more

Morgan Lewis

CFTC Releases No-Action Letter 14-144

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The letter modifies previous No-Action Letter 13-22, to expand relief for treasury affiliates entering into swaps on behalf of non-financial end-user affiliates that could otherwise elect the exception in section 2(h)(7) of...more

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