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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 ca...
In a typical “term loan B” (TLB) financing, the initial lenders expect to distribute the TLB paper to investors prior to funding. But what happens when that expectation cannot be met,...
The Treasury Department and IRS in April released a second set of proposed regulations governing tax incentives for investment in “qualified opportunity zones.” We expect the new rule...
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 serv...
The Supreme Court in Kisor v. Wilkie has declined to overrule Auer v. Robbins and Bowles v. Seminole Rock & Sand Co., instead narrowing deference to a federal agency’s interpretation of...
House Financial Services Committee Chair Maxine Waters (D-CA) has released a discussion draft of legislation to amend the SEC’s approach to considering and granting waivers to automatic...
The Supreme Court has updated an important Freedom of Information Act (“FOIA”) exemption for the digital age. In Food Marketing Institute v. Argus Leader Media, the Supreme Court thi...
The U.S. Securities and Exchange Commission, the U.S. Commodity Futures Trading Commission and the U.K. Financial Conduct Authority issued a joint statement Monday saying that so-called m...
On June 24, 2019, President Trump signed an Executive Order (“EO” or “Order”) imposing new economic sanctions on the Supreme Leader of Iran, Ayatollah Ali Khamenei, and the Irania...
On June 19, 2019, the Environmental Protection Agency issued the Affordable Clean Energy Rule (ACE Rule), replacing the Obama administration’s Clean Power Plan (CPP) for limiting greenh...