Ignacio A. Sandoval
Washington, D.C.
Is this you? As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.
Claim your profile
Articles by Ignacio A. Sandoval
SEC Further Delays Securities Lending and Short Position Reporting Compliance | JD Supra
On December 3, 2025, the Securities and Exchange Commission (SEC) issued an exemptive order extending the compliance dates for two rules: Rule 10c-1a (Reporting of Securities Loans) Rule 13f-2 (Short Position and Short Activity Reporting) The extension effectively pauses implementation for two years.
Clarity Act Coming Into Focus | JD Supra
The proposed Digital Asset Market Clarity Act would establish a comprehensive, top-down regulatory framework for digital assets that reflects a growing bipartisan push in Congress for clear oversight of the digital asset industry. On Nov.
FinCEN Issues FAQs Clarifying SAR Reporting Requirements | JD Supra
On October 9, 2025, the Financial Crimes Enforcement Network (FinCEN), along with the banking and credit union regulators, issued guidance in the form of frequently asked questions (FAQs) addressing the regulatory expectations for suspicious activity reports (SARs). The guidance is meant to clarify existing obligations rather than create new obligations.
SEC Short Interest and Securities Lending Reporting Rules Remanded | JD Supra
On August 25, the United States Court of Appeals for the Fifth Circuit remanded two rules adopted by the Gensler-era SEC: the Securities Lending Reporting Rule and the Short Interest Reporting Rules (the Rules).
Treasury Initiates Action Under GENIUS Act, Issues RFC on Detecting Illicit Finance | JD Supra
On August 18, the U.S. Department of the Treasury issued a Request for Comment (RFC) in a direct step toward implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) and in support of the Administration’s policy on digital assets outlined in Executive Order (E.O.) 14178.
FDIC Approves Use of Pre-Populated Customer Information During Account Opening | JD Supra
On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening the account verifies the information. This interpretation follows previous exemptive relief permitting all banks to obtain tax identification numbers (TINs) of new customers from third-party sources instead of directly from the customers.
What Does the White House Digital Asset Roadmap Mean for Crypto and Blockchain Innovation? | JD Supra
The President’s Working Group on Digital Asset Markets on July 30 released Strengthening American Leadership in Digital Financial Technology. This report, issued under January's Executive Order 14178, outlines a sweeping set of recommendations for the regulation of digital assets and blockchain technology in the United States. Below, we answer key questions about the report’s implications for businesses, financial institutions and investors. Why Was the Report Issued, and What Does It Prioritize?
What Does SEC Commissioner Peirce's July 9 Statement Mean for Tokenized Securities Regulation? | JD Supra
July 29, 2025 Joseph Perkins, Nathaniel Reisenburg, Ignacio Sandoval Orrick, Herrington & Sutcliffe LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: Although digitized initial offerings of securities may not be novel, blockchain tokenization of existing securities is still evolving.
Balancing The Promises And Perils Of Tokenizing Securities
By Ignacio Sandoval, Joseph Perkins and Nathaniel Reisenburg ( July 25, 2025, 4:42 PM EDT) -- The securities market may be entering uncertain territory as blockchain tokenization matures from digitizing collectibles and other real-world assets to the digitization of securities. Although digitized initial offerings of securities may not be novel, tokenizing existing securities is still evolving and presents several promises - but also potential legal perils.... Law360 is on it, so you are, too.
Balancing The Promises And Perils Of Tokenizing Securities
By Ignacio Sandoval, Joseph Perkins and Nathaniel Reisenburg ( July 25, 2025, 4:42 PM EDT) -- The securities market may be entering uncertain territory as blockchain tokenization matures from digitizing collectibles and other real-world assets to the digitization of securities. Although digitized initial offerings of securities may not be novel, tokenizing existing securities is still evolving and presents several promises — but also potential legal perils....
The Download: How Is Blockchain Driving Disruption? | JD Supra
Robert Leshner, a four-time founder and the CEO of Superstate, a fintech innovator bridging financial assets with crypto capital markets, talks with Orrick’s Albert Vanderlaan about the evolution of blockchain, the regulatory landscape and the sector’s future.
House STABLE Act Must Address State Interference in Stablecoins Original
The Bottom Line The STABLE Act, the House’s counterpart to the Senate’s GENIUS Act, similarly seeks to establish a clear regulatory framework for stablecoins, encouraging new market entrants. Under the current version of the bill, state regulators may indirectly limit the circulation of stablecoins by ordering licensed intermediaries to stop supporting them.
FINRA Securities Lending Reporting Rules Approved | JD Supra
The SEC has approved FINRA's 6500 rule series, which governs the Securities Lending and Transparency Engine (SLATE). The rules require some financial institutions to report securities loans to FINRA. They also require the public dissemination of certain loan details as required by the SEC's Rule 10c-1a on securities lending reporting. Timeline: The reporting requirements will be implemented by January 2, 2026, and dissemination requirements by April 2, 2026, unless the SEC extends these dates.
Short Interest Reports Due February 14 | JD Supra
Absent SEC or court action, institutional investment managers that meet or exceed certain thresholds face a February 14 deadline to file the first reports with the SEC on Form SHO. Form SHO, which was adopted with Rule 13f-2 under the Securities Exchange Act of 1934, became effective on January 2, 2024. Compliance with the rule began on January 2, 2025. The rules and reporting requirements cover "institutional investment managers" as defined in the Exchange Act.
SEC Amends Regulation NMS to Provide for Half-Penny Quoting in Securities and Reduction in Potential Rebate Money | JD Supra
The SEC voted unanimously to adopt changes to Regulation NMS (Reg. NMS) that address minimum pricing increments for securities, the access fees that securities exchanges charge, and increased transparency order prices. The Reg.
Supreme Court Curtails Use of Administrative Courts in SEC Enforcement Proceedings: What it Means for Other Agencies and What Happens Next | JD Supra
The U.S. Supreme Court has ruled that defendants in securities fraud cases brought by the SEC are entitled by the Seventh Amendment to have the SEC’s claims for civil money penalties decided by a jury and not in an administrative proceeding. The opinion is narrower than it might have been as the Court did not rule on two other questions the case presented.
RegFi Episode 36: The Intersection of AI and Securities Regulation | JD Supra
This week, RegFi co-hosts Jerry Buckley and Sasha Leonhardt welcome Ignacio Sandoval, a partner at Orrick and former special counsel in the SEC's Office of Chief Counsel, to explore the timely and complex subject of artificial intelligence in the securities industry. Their conversation covers developments at the intersection of AI technology and securities regulation and offers valuable insights into current applications, regulatory challenges and future trends.
US District Court Declares Corporate Transparency Act Is Unconstitutional
The US District Court for the Northern District of Alabama issued a landmark decision on March 1, 2024 in which it held that the Corporate Transparency Act (CTA) is unconstitutional. In the opinion, Judge Liles Burke held that the CTA does not fall within Congress’s powers to regulate commerce, oversee foreign affairs and national security, or impose taxes and related regulations.
SEC Adopts New Dealer Rules to Capture Liquidity Providers | JD Supra
On February 6, 2024, the US Securities and Exchange Commission (SEC) adopted new Rules 3a5-4 and 3a44-2 (the Final Rules) under the Securities Exchange Act of 1934 (the Exchange Act) to further define what it means to be engaged in the business of dealing in securities and government securities.
SEC Adopts New Dealer Rules to Capture Liquidity Providers
On February 6, 2024, the US Securities and Exchange Commission (SEC) adopted new Rules 3a5-4 and 3a44-2 (the Final Rules) under the Securities Exchange Act of 1934 (the Exchange Act) to further define what it means to be engaged in the business of dealing in securities and government securities.
SEC Adopts New Treasury Clearing Rules
On December 13, 2023, the US Securities and Exchange Commission (SEC) adopted rule amendments (Treasury Clearing Rules) designed to improve risk management in clearance and settlement and to facilitate additional central clearing for the US treasury market. The SEC first proposed the amendments on September 14, 2022. On December 8, we released a blog post about the adoption meeting.
SEC Adopts New Treasury Clearing Rules
On December 13, 2023, the US Securities and Exchange Commission (SEC) adopted rule amendments (Treasury Clearing Rules) designed to improve risk management in clearance and settlement and to facilitate additional central clearing for the US treasury market. The SEC first proposed the amendments on September 14, 2022. On December 8, we released a blog post about the adoption meeting.
SEC Set to Adopt Treasury Clearing Rules at Its Dec. 13 Meeting | JD Supra
At its next open meeting on December 13, 2023, the US Securities and Exchange Commission (SEC) is expected to adopt rules (the Treasury Clearing Rules) to improve risk management in clearance and settlement and facilitate additional central clearing for the US treasury market.
SEC Set to Adopt Treasury Clearing Rules at Its Dec. 13 Meeting
At its next open meeting on December 13, 2023, the US Securities and Exchange Commission (SEC) is expected to adopt rules (the Treasury Clearing Rules) to improve risk management in clearance and settlement and facilitate additional central clearing for the US treasury market.
SEC Adopts Short Interest Reporting Requirement | JD Supra
The Securities and Exchange Commission (SEC) adopted a new rule and form requiring certain persons to report short sale-related data to the SEC, which will in turn publish aggregate data. The SEC also adopted related amendments to the CAT NMS Plan to capture short sales effected by market makers in connection with bona fide market making activities. On October 13, 2023, the SEC adopted Rule 13f-2 under the Securities Exchange Act of 1934 (Exchange Act) and Form SHO.
SEC Adopts Short Interest Reporting Requirement
The Securities and Exchange Commission (SEC) adopted a new rule and form requiring certain persons to report short sale-related data to the SEC, which will in turn publish aggregate data. The SEC also adopted related amendments to the CAT NMS Plan to capture short sales effected by market makers in connection with bona fide market making activities. On October 13, 2023, the SEC adopted Rule 13f-2 under the Securities Exchange Act of 1934 (Exchange Act) and Form SHO.
SEC Finalizes Securities Lending Reporting Rule | JD Supra
The US Securities and Exchange Commission (SEC) has finalized a rule requiring certain parties to report their securities lending transactions to a registered national securities association (RNSA). The Financial Industry Regulatory Authority, Inc. (FINRA), currently the only RNSA, must now adopt rules implementing the infrastructure for such reporting and dissemination. The SEC adopted the new rule, Rule 10c-1a, under the Securities Exchange Act of 1934 (the Exchange Act) on October 13, 2023.
SEC Finalizes Securities Lending Reporting Rule
The US Securities and Exchange Commission (SEC) has finalized a rule requiring certain parties to report their securities lending transactions to a registered national securities association (RNSA). The Financial Industry Regulatory Authority, Inc. (FINRA), currently the only RNSA, must now adopt rules implementing the infrastructure for such reporting and dissemination. The SEC adopted the new rule, Rule 10c-1a, under the Securities Exchange Act of 1934 on October 13, 2023.
SEC Adopts Securities Lending Reporting Rules | JD Supra
On October 13, 2023, the US Securities and Exchange Commission (SEC) adopted Rule 10c-1a requiring the reporting and dissemination of certain details regarding securities lending transactions. New Rule 10c-1a under the Securities Exchange Act of 1934 requires generally that specified information about securities loans be reported to the Financial Industry Regulatory Authority Inc.
SEC Scraps Ticker Tape Concept for Securities Loans, Ignites
The US Securities and Exchange Commission recently adopted a tempered version of its November 2021 proposed rule aimed at bringing greater transparency to securities lending. Among its aspects, the final rule eased the timeframe needed for public disclosure of more granular data to 20 days after the loan is made. Speaking to Ignites, partner Ignacio Sandoval said that “it’s not going to be a ticker tape for securities lending.
SEC Adopts Securities Lending Reporting Rules
On October 13, 2023, the US Securities and Exchange Commission (SEC) adopted Rule 10c-1a requiring the reporting and dissemination of certain details regarding securities lending transactions. New Rule 10c-1a under the Securities Exchange Act of 1934 requires generally that specified information about securities loans be reported to the Financial Industry Regulatory Authority Inc.
SEC Poised to Shine Light on Short Selling with Stock Loan Disclosure, Financial Times
Partner Ignacio Sandoval spoke with the Financial Times in advance of the US Securities and Exchange Commission’s vote on a proposed rule that would create a sweeping new reporting and disclosure regime for participants in the securities lending markets.
SEC Amends Rules for Reporting Beneficial Ownership on Schedules 13D and 13G
The US Securities and Exchange Commission (SEC) adopted amendments on October 10, 2023 to the rules governing beneficial ownership reporting on Schedules 13D and 13G and provided guidance on the rules’ application. The revisions and guidance generally shorten the period for making both initial filings and amendments, clarify requirements for derivative securities and considerations regarding acting as a group, and require that certain information be provided in a structured data format.
SEC Schedules Vote on Sec-Lending Rule Proposal, Ignites
In an article previewing an upcoming vote from the US Securities and Exchange Commission (SEC) on a 2021 rule proposal that could potentially create a new reporting and disclosure regime for participants in the securities lending markets, partner Ignacio Sandoval spoke with Ignites about some of the anticipated changes that could be seen in the final rule.
US Corporate Transparency Act: Impact on Private Funds and Venture Capital Funds
The final rule of the Financial Crimes Enforcement Network (FinCEN) implementing the Corporate Transparency Act’s (CTA’s) beneficial ownership requirements will become effective on January 1, 2024. The final rule may apply to some of the entities within a private fund structure unless such entities are restricted to come within applicable exemptions before reporting dates becomes effective.
How Will the US Corporate Transparency Act Impact Sovereign Wealth Funds and Other Non-US Government Institutions? | JD Supra
The final rule of the Financial Crimes Enforcement Network implementing the Corporate Transparency Act’s beneficial ownership requirements will become effective on January 1, 2024. Absent further guidance, sovereign wealth funds and similar non-US governmental institutions need to evaluate whether and to what extent the rule will apply to them, whether any exemptions are available, and whether operations can be restructured in order to take advantage of an available exemption.
How Will the US Corporate Transparency Act Impact Sovereign Wealth Funds and Other Non-US Government Institutions?
The final rule of the Financial Crimes Enforcement Network implementing the Corporate Transparency Act’s beneficial ownership requirements will become effective on January 1, 2024. Absent further guidance, sovereign wealth funds and similar non-US governmental institutions need to evaluate whether and to what extent the rule will apply to them, whether any exemptions are available, and whether operations can be restructured in order to take advantage of an available exemption.
How Will the US Corporate Transparency Act Impact Sovereign Wealth Funds and Other Non-US Government Institutions?
The final rule of the Financial Crimes Enforcement Network implementing the Corporate Transparency Act’s beneficial ownership requirements will become effective on January 1, 2024. Absent further guidance, sovereign wealth funds and similar non-US governmental institutions need to evaluate whether and to what extent the rule will apply to them, whether any exemptions are available, and whether operations can be restructured in order to take advantage of an available exemption.
New York Weighs Requiring Public Disclosure of LLC Ownership Information
The New York State Assembly recently passed the LLC Transparency Act (the LLC Act). If signed into law by New York Governor Kathy Hochul, the LLC Act would require limited liability companies (LLCs) formed or registered to do business in New York to disclose their beneficial owners to the New York State government, which would make this information available in a public database and potentially fundamentally change how businesses are organized in New York.
New York Weighs Requiring Public Disclosure of LLC Ownership Information
The New York State Assembly recently passed the LLC Transparency Act (the LLC Act). If signed into law by New York Governor Kathy Hochul, the LLC Act would require limited liability companies (LLCs) formed or registered to do business in New York to disclose their beneficial owners to the New York State government, which would make this information available in a public database and potentially fundamentally change how businesses are organized in New York.
SEC Proposes Sweeping Rules on Broker-Dealer and Investment Adviser Technology Use Original
The US Securities and Exchange Commission (SEC) proposed on July 26, 2023 new rules designed to address conflicts of interest from the use of predictive data analytics in “investor interactions” by broker-dealers and investment advisors (the PDA Rules).
Broker-Dealers Must Prepare For Daily Calculation Rules
By Ignacio Sandoval (July 19, 2023, 5:09 PM EDT) -- On July 12, the U.S. Securities and Exchange Commission proposed amendments[1] to Rule 15c3-3 - the Customer Protection Rule - under the Securities Exchange Act to require certain broker-dealers to increase the frequency with which they perform computations of the net cash they owe to customers and other broker-dealers from weekly to daily.... Law360 is on it, so you are, too.
Broker-Dealers Must Prepare for Daily Calculation Rules, Law360
Outside Publication Broker-Dealers Must Prepare for Daily Calculation Rules, Law360 July 19, 2023 Partner Ignacio Sandoval is featured in a Law360 article covering the US Securities and Exchange Commission’s proposed changes to the Customer Protection Rule, which would impact about 63 carrying broker-dealers and potentially require more frequent deposits into customer and proprietary accounts of broker-dealers’ reserve bank accounts. Read the full Law360 article >>
A Shift Toward a Holistic Approach to Digital Assets Regulation | JD Supra
The growth of digital assets presents a challenge for global regulators, but also an opportunity to facilitate development of revolutionary access to the modern financial system. A successful way forward will require international collaboration and alignment of regulatory goals. Part 1 of this article series examined the regulatory landscape in the wake of several high-profile crypto bankruptcies.
SEC Proposes Daily Reserve Account Calculation for Certain Broker-Dealers | JD Supra
The US Securities and Exchange Commission proposed changes to the Customer Protection Rule, which would impact about 63 carrying broker-dealers and potentially require more frequent deposits into customer and PAB reserve bank accounts.
A Shift Toward a Holistic Approach to Digital Assets Regulation
The growth of digital assets presents a challenge for global regulators, but also an opportunity to facilitate development of revolutionary access to the modern financial system. A successful way forward will require international collaboration and alignment of regulatory goals. Part 1 of this article series examined the regulatory landscape in the wake of several high-profile crypto bankruptcies.
SEC Proposes Daily Reserve Account Calculation for Certain Broker-Dealers
The US Securities and Exchange Commission proposed changes to the Customer Protection Rule, which would impact about 63 carrying broker-dealers and potentially require more frequent deposits into customer and PAB reserve bank accounts.
A Shift Toward a Holistic Approach to Digital Assets Regulation
The growth of digital assets presents a challenge for global regulators, but also an opportunity to facilitate development of revolutionary access to the modern financial system. A successful way forward will require international collaboration and alignment of regulatory goals. Part 1 of this article series examined the regulatory landscape in the wake of several high-profile crypto bankruptcies.
New York Attorney General Proposes Comprehensive and Restrictive Digital Assets Bill | JD Supra
New York Attorney General Letitia James introduced on May 5, 2023 a proposed bill that, if enacted, would significantly tighten regulation over digital asset market participants and exchanges. While the New York State legislative session ended on June 8 without the introduction or passage of the proposed legislation, we anticipate that the current proposal or a new version will be introduced during the next legislative session or discussed with legislators in other states (i.e., shopped around).
New York Attorney General Proposes Comprehensive and Restrictive Digital Assets Bill
LawFlash June 21, 2023 New York Attorney General Letitia James introduced on May 5, 2023 a proposed bill that, if enacted, would significantly tighten regulation over digital asset market participants and exchanges.
Show More
loading
Actions
Is this you?
As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.Get in touch with Ignacio A.
Contact Ignacio A., search articles and posts on X, monitor coverage, and track replies from one place.
Learn more about Muck Rack