Dodd-Frank

Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition

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Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Fall Focus Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and will provide another update in the next quarter.

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The Volcker strip – making banking less regulated again

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US regulators have disclosed the much awaited revision of the Volcker Rule that had been taken on by the Trump administration. Wall Street has undoubtedly received a huge win, but who is likely to bear the losses?

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IM- the breakdown (averted)

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As expected, ISDA have communicated a more granular breakdown of
estimates for the likely population of the new IM phases 5 and 6, via relevant
working groups. These have been replicated and published by a number of third
party firms. Although all the numbers are estimated, there seems to both a lack
of mathematical rigour and some confusion between the population and threshold
estimates.

The estimates are as follows:

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Trade and Transaction Reporting 2019 – the mid-year update

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It’s

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IM Phase 5 to bifurcate

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Confirming recent market rumours, BCBS\IOSCO have today announced their recommendation to stagger IM Phase 5 implementation over a two year period. An adjusted Phase 5 will apply to firms with an AANA equal to or greater than USD\EUR 50bn and less than 750bn.

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Visual Memorandum: SEC’s Security-Based Swap Capital, Margin and Segregation Rules

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On June 21, 2019, the SEC adopted security-based swap (SBS) capital, margin and segregation requirements (the SEC Rules) for SBS dealers (SBSDs) and major SBS participants, revised the capital and segregation requirements for broker-dealers that are not SBSDs to the extent they engage in SBS activities, and increased the minimum capital requirements for broker-dealers authorized to use internal models to compute net capital. The SEC Rules do not start the registration or compliance clock for SBSDs.

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Additional Clarity Could be Coming on the CFPB’s “Abusive” Acts or Practices Authority—But Don’t Hold Your Breath

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The main lesson from the CFPB symposium on “abusive acts or practices” is that there won’t be any clarity anytime soon.  In response to long-lasting concerns from the financial services industry that the indefinite scope and meaning of what amounts to an “abusive” act or practice generates uncertainty and impedes innovation, the agency publicly announced in its Fall 2018 Unified Agenda that it was considering rulemaking or “other activities” to help clarify the meaning of this

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Testimony to US Senate Committee on Agriculture

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Written Statement of Scott O’Malia

Chief Executive Officer

International Swaps and Derivatives Association

US Senate Committee on Agriculture, Nutrition and Forestry

June 25, 2019

Chairman Roberts, Ranking Member Stabenow and Members of the Committee, ISDA is grateful for the opportunity to submit a written statement on the reauthorization of the Commodity Exchange Act (CEA)[1].

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Giancarlo Races to the Cross Border Line

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In his final speech to the FIA, Chairman Giancarlo last week discussed three cross border swaps proposals that he will schedule for Commission consideration before he steps down on July 15.  Giancarlo has been particularly focused during his tenure on advancing a cross border swaps framework based on regulatory deference for jurisdictions that have adopted comparable G-20 swaps reforms—a position he advocated in a White Paper

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Davis Polk Financial Services Regulatory Reform Tool—Summer Spotlight Edition

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Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Summer Spotlight Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and will provide another update in the next quarter.

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