This Legal Update explores why, in order for an underlying loan to be included in a warehouse facility’s borrowing base, the underlying loan cannot be margin stock....more
In Consultation Paper 13/23 (CP 13/23), the UK’s Prudential Regulation Authority (“PRA”) sets out its “Margin requirements for non-centrally cleared derivatives: Amendments to BTS 2016/2251.”...more
In another sign of progress, the Federal Deposit Insurance Corporation (FDIC) proposed easing a rule that requires banks to put cash aside to safeguard derivatives trades among affiliates. The proposal would remove the...more
The Securities and Exchange Commission ("SEC") has adopted rules under the Securities Exchange Act (the "SEA") establishing (i) capital and margin requirements applicable to broker-dealers entering into security-based swaps...more
CFTC Comparability Determination on EU Margin Requirements and a Common Approach on Trading Venues - On October 13, 2017, the U.S. Commodity Futures Trading Commission ("CFTC") announced determinations by the CFTC and the...more
Editor's Note - In This Issue. The New York Department of Financial Services issued its highly anticipated cybersecurity regulation in its final form, the Securities and Exchange Commission (SEC) issued updated guidance...more
Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more