Reg CA would create tailored offering exemptions and disclosure rules for some primary offerings of crypto assets, but would provide less certainty to intermediaries and secondary markets.
The CFTC’s proposal acknowledges the ways in which novel products may require novel market structures with affiliations between registrants, while establishing minimum standards for mit...
Articles & Books
Thomson Reuters’ Regulation of Swaps and Security-Based Swaps in the United States
Davis Polk partner Gabe Rosenberg and counsel Tyler Senackerib served as co-editors, along with CIBC’s William Meehan, of the 2026 edition of Regulation of Swaps and Security-Based Swap...
The SEC and CFTC have jointly requested public comment as they consider updating classification rules for innovative financial products, including event contracts and perpetual contracts.
The CFTC’s Division of Enforcement announced its new cooperation policy for corporate enforcement matters. The advisory seeks to incentivize companies to voluntarily disclose, cooperate...
The SEC has issued a much-anticipated interpretation regarding when the federal securities laws apply to certain types of crypto assets and transactions. It is an important step forward, ...
Davis Polk partners Gabe Rosenberg and Zach Zweihorn and associate Billy Hicks authored “3 reasons we need digital asset market structure legislation” in Law360. In the article, the a...
The OCC finalized a rule clarifying that national trust banks may engage in non-fiduciary activities but left open the question of whether a national trust bank must engage in a minimum a...
The OCC proposed a rule that would eliminate any uncertainty as to whether national trust banks can engage in non-fiduciary activities. If adopted, the proposal would align language in th...
