On April 12, 2011, the U.S. banking regulators proposed rules regarding the capital and margin requirements applicable to uncleared swaps.  In general, the proposed rules would not impose...

After many years of negotiations with the SEC staff, FINRA recently proposed for comment Rule 3190 to clarify the scope of the obligations and supervisory responsibility of member firms f...

The U.S. SEC has issued a no-action letter confirming that non-U.S. issuers that file financial statements in IFRS as issued by the IASB will not be required to provide financial statemen...

Requiring systemically important financial institutions to prepare living wills has the potential to be one of the most effective tools in improving risk management, reducing systemic ris...

Davis Polk is pleased to announce the first installment of the “Davis Polk Dodd-Frank Rulemaking Progress Report.” This short presentation, to be issued monthly, uses empirical data t...

On March 30, 2011, the SEC proposed rules to implement the Dodd-Frank Act’s requirements regarding the independence of compensation committees and their advisers. The proposed rules are...

Yesterday seven federal agencies jointly finalized a proposed rule under Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that would subject financial institut...

On March 23, 2011, the FDIC published its second notice of proposed rulemaking to implement its new Orderly Liquidation Authority (OLA) under Title II of the Dodd-Frank Act. The Second NP...

Earlier today, the Supreme Court issued an opinion in Matrixx Initiatives, Inc. v. Siracusano. The case involved Matrixx’s lack of disclosure of reports that its Zicam nasal spray produ...

Last week House Republicans announced that they are drafting five bills to eliminate or change parts of the Dodd-Frank Act.  One of the five is the elimination of the provision to disclos...