On August 13, 2012, the U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) issued a joint final rulemaking in conjunction with the U.S. Securities and Exchange Commission (“SEC”) further defining the term “Swap” as required under Title VII of the…

Earlier this year, the Consumer Financial Protection Bureau (“CFPB”) published a Bulletin signaling its intent to regulate and exercise enforcement authority over service providers to financial institutions. Pursuant to Title X of the Dodd-Frank Wall Street Reform and Consumer Protection…

On April 5, 2012, President Obama signed H.R. 3606, the Jumpstart Our Business Startups (JOBS) Act (the “Act”), into law. The Act is intended to help smaller companies access the U.S. capital markets by relaxing certain regulatory compliance and disclosure…

With the January 4, 2012 recess appointment of former Ohio Attorney General Richard Cordray as its first director, the Consumer Financial Protection Bureau quickly is coalescing around an aggressive regulatory agenda.  What can large financial institutions and other participants in…

On March 8, 2012, the House of Representatives (the “House”) passed H.R. 3606, the Jumpstart Our Business Startups (JOBS) Act (the “Bill”), by a vote of 390 to 23. The Bill consists of a collection of bills that have been…

On March 7, 2012, the Staff of the Securities and Exchange Commission (the “Staff”) issued responses to a series of no-action requests seeking to exclude shareholder proxy access proposals. These no-action responses represent the first significant guidance from the Staff…

On February 15, 2012, the Securities and Exchange Commission (“SEC”) adopted new rules under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), as required by Section 418 of the Dodd-Frank Wall Street Reform and Consumer Protection Act…