Developments in Securities Regulation, Corporate Governance, Capital Markets, M&A and Other Topics of Interest

CFTC Issues Proposed Rules on Financial Resource Requirements for DCOs and SIDCOs and Conflicts of Interest


On October 1, 2010, the CFTC issued proposed rules on financial resource requirements for derivative clearing organizations (“DCOs”) and systematically important DCOs (“SIDCOs”).  The CFTC also issued proposed rules on conflicts of interest.  The rulemaking is permitted under the Dodd-Frank Act.   Each proposed rule is analyzed below. Financial Resource Requirements... Read More

Topics: Banking

CFTC Adopts Interim Final Rule on Reporting of Pre-Enactment Swaps


Beating the deadline (October 20, 2010) for the first of its required Dodd-Frank rulemakings by more than two weeks, the CFTC has announced publication of its required interim final rule for the reporting of pre-enactment swap transactions. The basic requirements of the reporting rule are outlined below. What Counterparties are... Read More

Topics: Banking, Derivatives, Energy, Insurance, Uncategorized

Examples of Dodd-Frank Disclosures in SEC Filings


Dodd-Frank disclosures have begun to proliferate in SEC filings.  We reviewed many recent filings and disclosures fall into the following general categories:  internal controls, forward looking statements,  executive compensation, regulatory matters and risk factors.  Examples are set forth below. Internal Controls PDC 2004-D Limited Partnership  (Filed September 30, 2010) Internal... Read More

Topics: Public Companies and Securities