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Articles by Mark A Sater
Davis Polk Discusses SEC No-Action Statement on Custody of Digital Asset Securities
A recent SEC conditional no-action position (the “No-Action Statement”) has further opened the regulatory door to trading of digital asset securities (“DAS”), by allowing certain limited purpose DAS-only broker-dealers to maintain custody of these securities on behalf of customers.
SEC Takes No-Action Position on Custody of Digital Asset Securities by Special Purpose Broker-Dealers
A recent SEC conditional no-action position (the “No-Action Statement”) has further opened the regulatory door to trading of digital asset securities (“DAS”), by allowing certain limited purpose DAS-only broker-dealers to maintain custody of these securities on behalf of customers. Efforts to meet the SEC staff’s prior guidance that broker-dealers generally could not custody DAS for customers triggered somewhat cumbersome workaround attempts.
SEC Issues Order Requiring Changes to NMS Plan Governance
The Securities and Exchange Commission acted on the first of its proposals to substantially revamp the regulations concerning equity market data by issuing an order directing the national securities exchanges and the Financial Industry Regulatory Authority to propose a new National Market System equity market data plan.
SEC Proposes Changes to Market Data Infrastructure
The SEC recently proposed amendments to the current market data infrastructure to expand the content required to be published on the consolidated tape and decentralize the collection, consolidation, and dissemination of market data through the introduction of proposed competing consolidators and self-aggregators. Please see our client memorandum for more details. Law Clerk Charles Klug contributed to this blog post. View as a PDF
Enforcement of financial services regulations in USA | Lexology
Enforcement Investigatory powers What powers do national financial services authorities have to examine and investigate compliance? What enforcement powers do they have for compliance breaches? How is compliance examined and enforced in practice? The Banking Regulators, the CFPB, the Markets Regulators and SROs have broad authority to examine the entities they supervise (and, in some cases, their affiliates) for compliance with applicable laws, rules and regulations.
Compliance programmes for financial services firms in USA | Lexology
Compliance programmes Programme requirements What requirements exist concerning the nature and content of compliance and supervisory programmes for each type of regulated entity? The Banking Regulators, who act as prudential supervisors, are focused on monitoring the safety and soundness of depository institutions and their holding company system in a comprehensive manner.
Financial Services Compliance in the USA | Lexology
Use the Lexology Getting The Deal Through tool to compare the answers in this article with those from other jurisdictions. Regulatory framework Regulatory authorities What national authorities regulate the provision of financial products and services?
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