Guy C. Dempsey Jr.

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On May 22, the Financial Industry Regulatory Authority (FINRA) issued an open invitation for member firms and other interested parties to provide views and information about the security-based swap (SBS) market, with particular focus on broker-dealer SBS activities and the application of FINRA rules to those activities. The invitation, which is not a mandatory information request, includes the following questions:…
Continue Reading FINRA Requests Comments on Security-Based Swaps

On May 19, the Commodity Futures Trading Commission’s Global Markets Advisory Committee approved a report that contains several recommendations for action by the CFTC with respect to the implementation of its initial margin (IM) rules for uncleared swaps. The recommendations are focused on the unique challenges faced by small end users of swaps and entities that engage in swap activity through separate managed accounts (SMAs).
Continue Reading CFTC GMAC Recommendations Concerning Initial Margin for Swaps

The International Swaps and Derivatives Association, Inc. (ISDA) has launched a new webpage containing information about interest rate benchmark reform and the transition away from the use of interbank offered rates (IBORs, including LIBOR) as floating rates in swap transactions. The page and subsequent materials are available to everyone, not just ISDA members.
Continue Reading ISDA Launches Benchmark Reform Information Source

On Friday, April 3, the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) announced another delay in the implementation of the global implementation of mandatory initial margin for uncleared swaps. The initial margin compliance date for Phase 5 will now be September 1, 2021. The compliance date for Phase…

On January 30, the Board of Governors of the Federal Reserve System (the Board) adopted a final rule to simplify and increase the transparency of determinations of when a company has the ability to exercise a controlling influence over another company for purposes of the Bank Holding Company Act or the Home Owners’ Loan Act. The rule takes the form of amendments to Regulation Y. …
Continue Reading Federal Reserve Adopts Revamped Standards for Determinations of Bank Control

On January 30, the five regulators responsible for Section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) each approved a set of amendments intended to modify and clarify the covered fund provisions of the regulations implementing the Volcker Rule. (The five regulators are the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission and the Securities and Exchange Commission.) …
Continue Reading Volcker Rule Regulators Propose Changes to Covered Fund Rules

On November 25, the Securities and Exchange Commission’s Division of Trading and Markets issued guidance intended to facilitate certain substituted compliance applications submitted by non-US security-based swap dealers and/or major security-based swap participants (Guidance). …
Continue Reading SEC Issues Guidance on Substituted Compliance Applications by Non-US Security-Based Swap Dealers and Major Security-Based Swap Participants