Dodd-Frank

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On Dec. 10, 2013, the Commodity Futures Trading Commission (“CFTC”), Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (the “Board”), Office of the Comptroller of the Currency and Securities and Exchange Commission (“SEC”) (collectively, the “Agencies”) issued a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection…

On Dec. 10, 2013, the CFTC, FDIC, Federal Reserve Board, OCC and SEC issued a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Act, which is commonly referred to as the “Volcker Rule.” The Volcker Rule restricts the proprietary trading and private investment fund activities of U.S. banks and their affiliates, as…

The Commodity Futures Trading Commission (“CFTC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Federal Reserve Board (“Fed”) each announced today that they will discuss, and potentially approve, a final draft of the Volcker Rule at their respective meetings on Tuesday, Dec. 10, 2013. The CFTC meeting will commence at 9:30 a.m. and the others…

Asset gathering has become more competitive and challenging for hedge fund managers. It has also become more interesting to regulators. The challenge for managers is to understand the new regulatory requirements and prepare for what is coming next.

Click here to read my column that appeared in HFMWeek discussing hedge fund marketing and the SEC’s

The Dec. 31, 2012 deadline for adhering to the ISDA August 2012 Dodd-Frank Protocol published by the International Swaps and Derivatives Association (“ISDA”) has been delayed until May 1, 2013.

Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the Commodity Futures Trading Commission (“CFTC”) issued a number of business-conduct rules…

Checklists are popular as the year end approaches. For hedge fund managers, Dodd-Frank and the Alternative Investment Fund Managers Directive make these checklists even more challenging. Most managers have devoted more resources than ever before to understanding and complying with all of the applicable requirements. But when it comes to regulatory compliance, well-intentioned managers may…

ISDA has included an Addendum I (the “Addendum”) to the ISDA August 2012 Dodd-Frank Protocol Questionnaire (“Questionnaire”), which provides provisions addressing changes to certain “eligible contract participant” categories that will become effective on Dec. 31, 2012. The Addendum is relevant to any OTC Derivative Counterparties that are “commodity pools” and who (a) rely upon the…

The Depository Trust & Clearing Corporation (DTCC) and SWIFT have launched a Web portal to begin assigning CFTC Interim Compliant Identifiers (CICIs) as required by the CFTC’s Data and Recordkeeping Rule. All swap counterparties are required to be identified by a CICI. All swap counterparties currently adhering to the ISDA Dodd-Frank Protocol are required to…