How did we get here? On September 11, 2020, the SEC adopted new rules to “update and expand the statistical disclosures” that bank holding companies, banks, savings and loan holding companies...
From where I sit, the SEC under the chairmanship of Jay Clayton has generally done a good job for public companies. It has adopted a number of rules and amendments that make disclosure more eff...
https://www.thesecuritiesedge.com/2020/08/13f-proposal-the-sec-can-and-should-do-better/
For several years we’ve been advocating that state-chartered banks that do not require a bank holding company should ditch the holding company structure. It now appears that several banks ar...
Earlier this month, the Federal Reserve proposed changes to its guidance on corporate governance for banking organizations. The proposals suggest a new approach to corporate governance that cou...
Earlier this week, the Financial Crimes Enforcement Network (“FinCEN”) proposed a rule that would require investment advisers registered with the Securities Exchange Commission (“SEC”) to...
There have been a number of press reports in recent days about attempts by the new Republican majority to repeal all or part of Dodd-Frank. Depending upon whom you choose to believe (assuming y...
https://www.thesecuritiesedge.com/2015/01/bad-laws-make-hard-cases/
The Foreign Account Tax Compliance Act (“FATCA”) is a US law designed to counter offshore tax avoidance by US persons. Controversial because of its wide-ranging breadth and application to non...
https://www.thesecuritiesedge.com/2014/05/fatca-what-it-is-and-why-it-may-apply-to-your-business/
The SEC continues to increase its focus on cybersecurity preparedness. As we have reported in prior blogs here and here, we believe that cybersecurity will become an increasingly important elemen...
https://www.thesecuritiesedge.com/2014/05/sec-increases-focus-on-cybersecurity/
Generally speaking, the Bank Secrecy Act (“BSA”) requires financial institutions in the United States to assist U.S. government agencies to detect and prevent money laundering. But while anyo...
https://www.thesecuritiesedge.com/2014/05/bank-secrecy-act-broker-dealers-must-also-comply/
As we blogged about last August, Section 913 of the Dodd-Frank Act directed the SEC to study the need for establishing a new, uniform, federal fiduciary standard of care for brokers and investmen...
https://www.thesecuritiesedge.com/2014/03/uniform-fiduciary-standard-for-broker-dealers-an-update/