Corporate & Financial Weekly Digest

On September 16, the Securities and Exchange Commission adopted amendments to the Securities Exchange Act of 1934 (Exchange Act) Rule 15c2-11 to modernize the rule, including by recognizing advances in communications technology. The rule requires broker-dealers to review key, basic issuer information before initiating or resuming quotations for the issuer’s security in the over-the-counter (OTC) market.…
On September 15, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Clearing and Risk (DCR) and Division of Swap Dealer and Intermediary Oversight (DSIO) issued CFTC Letter No. 20-28, providing supplemental guidance and further no-action relief with respect to the treatment of separate accounts by futures commission merchants (FCMs). Initial guidance and relief was set out in CFTC Letter No. 19-17, which was issued in July 2019.…
On September 11, the Commodity Futures Trading Commission (CFTC) announced that the Division of Swap Dealer and Intermediary Oversight (DSIO) and the Division of Market Oversight (DMO) had issued CFTC Letter No. 20-26, further extending certain elements of the temporary no-action relief issued in response to the COVID-19 pandemic that are set to expire on September 30. The extended relief expires on January 15, 2021.…
On September 15, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) granted no-action relief to Tassat Derivatives LLC, a CFTC-registered swap execution facility (SEF), from SEF reinstatement requirements under CFTC Regulation 37.3(d). The no-action relief set out in CFTC Letter No. 20-27 is subject to certain conditions.…
In connection with the requirements set forth in Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Section 1071), the Consumer Financial Protection Bureau (CFPB) released on September 15, both a high-level summary (Summary) and a more detailed outline of the proposals it is considering (Outline) to implement Section 1071’s mandate that the CFPB require financial institutions to “compile, maintain, and submit to the [CFPB] certain data on applications for credit for…