Podcast: CFTC Issues LIBOR Transition Relief for Swaps
LEGAL ALERT: CFPB Issues Proposed Revisions to No-Action Letter Policy
Open for Business: SEFs Navigate the New Regulatory Environment
On Sept. 2, the Securities and Exchange Commission’s (SEC) Division of Trading Markets and the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk issued a joint...more
Jay Clayton to step down as SEC Chairman at the end of this year - Securities and Exchange Commission Chairman Jay Clayton will step down at the end of this year, according to a November 16, 2020, announcement. This...more
The U.S. Securities and Exchange Commission (“SEC”) issued a statement in response to the Wyoming Division of Banking’s No-Action Letter on Custody of Digital Assets and Qualified Custodian Status....more
It was a year filled with tantalizing tidbits and many loose ends. 2019 marked the 10th year since blockchain technology was released into the wild by its still unknown inventor, Satoshi Nakamoto, who mined the first bitcoin...more
Digital assets and Blockchain technologies which were once described as the tools of criminals, are now a key part of efforts by traditional financial services firms to transform their businesses and innovative firms looking...more
On October 28, 2019, the SEC's Division of Trading and Markets granted no-action relief for a limited period of time to Paxos Trust Company, LLC from registration as a clearing agency under Section 17A(b)(1) of the Securities...more
On October 28, 2019, Paxos Trust Company, LLC (Paxos) received a time-limited (two-year) No-Action Letter from the Division of Trading and Markets of the U.S. Securities and Exchange Commission (SEC). This No-Action Letter...more
In this issue of The Distributed Ledger, we discuss the IRS' warning letters for over 10,000 cryptocurrency holders, the SEC's settlement with a blockchain company regarding unregistered ICO transactions, and a European...more
The SEC Division of Corporate Finance recently issued a no-action letter to Pocketful of Quarters, confirming that the Division will not recommend any enforcement action if the company sells its blockchain-based tokens...more
BROKER-DEALER - FINRA Proposes to Ease Restrictions on Initial Equity Public Offerings and New Issues - The Financial Industry Regulatory Authority (FINRA) is proposing to amend its Rule 5130 and Rule 5131 to ease ...more
U.S. Developments - Regulatory Developments - SEC Issues Second No Action Letter for Blockchain-Based Project - On July 25, 2019, the staff of U.S. Securities and Exchange Commission (SEC) issued its second ever...more
SEC Issues No-Action Letter, Financial Services Firms and Major Exchanges Make Moves, New Products Launched in Europe - This week, the U.S. Securities and Exchange Commission (SEC) issued to Pocket Full of Quarters Inc....more
During the previous quarter, the SEC proposed new rulemaking to reduce the number of smaller companies that become subject to enhanced reporting requirements through “accelerated filer” and “large accelerated filer” status....more
On April 24, 2019, Skadden hosted a webinar titled “The Current State of Cryptocurrency Enforcement and Securities Litigation.” The presented topics largely focused on the SEC’s evolving regulatory approach to cryptocurrency...more
TurnKey No-Action Letter and Framework Publication - The Securities and Exchange Commission ("SEC") recently issued highly anticipated guidance to assist market participants in determining whether a digital asset is...more
REGULATORY UPDATES - Financial Industry Regulatory Authority (“FINRA”) Releases Its 2019 Priorities - On January 22, 2019, FINRA released its Annual Risk Monitoring and Examination Priorities Letter, which highlighted the...more
In this issue, we examine the release of the much-anticipated Strategic Hub for Innovation and Financial Technology (FinHub) guidance for analyzing how U.S. federal securities laws apply to initial coin offerings, the...more
On April 3, 2019, Finhub, the SEC’s Strategic Hub for Innovation and Financial Technology, released the “Framework for ‘Investment Contract’ analysis of digital assets” (the “Framework”) providing principles for analyzing...more
U.S. Developments - Regulatory Updates - SEC Releases “No-Action Letter” Stating Turnkey Jet ICO Tokens Are Not Securities and Releases “Framework for ‘Investment Contract’ Analysis of Digital Assets” - The U.S....more
The U.S. Securities and Exchange Commission (SEC) Strategic Hub for Innovation and Financial Technology (FinHub) published a framework on April 3, 2019, for analyzing whether a digital asset is offered and sold as a security...more
While SEC FinHub’s new framework announced last week for identifying crypto-securities suggests continued resistance for those using digital assets to access capital markets, an SEC no-action letter issued the same day to...more
In recent guidance the US Securities and Exchange Commission provides detailed “investment contract” analysis applicable to digital assets, which will have a significant impact on the design, transfer, sale, and trading of...more
On April 3, 2019, the Strategic Hub for Innovation and Financial Technology (“FinHub”) of the U.S. Securities and Exchange Commission (“SEC”) published two pieces of guidance on when a blockchain-enabled digital asset will,...more
(You Say Security, I Say Utility; Midtrial Acquittal) - The Securities and Exchange Commission’s FinHub group issued guidance last week, providing a checklist of characteristics to help determine whether a cryptoasset may...more
Late last week, the SEC issued a no-action letter widely hailed as its first on a blockchain-based digital token for private jet services. ...more