Investment Advisor Registration Deadline Causing Confusion In the Private Fund Investment Advisers Registration Act of 2010, Congress adopted changes to the Investment Advisers Act of 1940 to require many more managers of hedge funds or private equity funds to register as investment advisers. Registered advisers are expected to update their books and records practices in order to…

SEC to provide guidance on Dodd-Frank requirements and extend temporary rules under the Exchange Act. As previously noted, the Securities Exchange Commission granted itself an extension to finalize the rules mandated by Dodd-Frank.   The Commission announced that it will shortly clarify which provisions of Title VII will automatically go into effect on July 16, alter…

FIA and ISDA Publishes Documentation for Cleared Swaps in an effort to add structure to OTC market pending full implementation of Dodd-Frank Act and similar regulation in foreign jurisdictions. In anticipation of the clearing requirements in Dodd-Frank, each of the major clearing houses published proprietary agreements with the intent to best fit OTC swaps clearing…

Concerns Facing the OTC Derivatives Market in the Absence of a Workable Regulatory Structure The delay of Title VII rulemaking in the Dodd-Frank Act, arguably one of the largest pieces of financial legislation to come out of Congress since the Great Depression, is concerning to those involved in all aspects of the OTC market. On…

A Dodd-Frank Overview According to the U.S. Securities and Exchange Commission (SEC), “Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) addresses the gap in U.S. financial regulation of OTC swaps by providing a comprehensive framework for the regulation of the OTC swaps markets.” Dodd-Frank goes into effect July 16, 2011 (360 days after it…

The Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) continue to issue regulations implementing the OTC derivatives provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).  In a Q&A, Robin Powers of the Rimon Law Group discusses Title VII of Dodd-Frank and its impact on margin/collateral posed by End-Users. This article appeared…