CCMR Report on Financial Transaction Taxes

For over 300 years, financial transaction taxes (“FTTs”) have been proposed, discussed, and implemented in various forms across global financial markets. And for over 300 years, FTTs have been a failure wherever imposed, frequently failing to raise the promised revenues, while simultaneously damaging the efficiency of the affected markets. Recent proposals for an FTT in […]

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Committee Submits Comment Letter to IOSCO and the FSB Regarding IOSCO’s Leverage Report

On August 26, 2019, the Committee submitted a comment letter to the International Organization of Securities Commissions (“IOSCO”) and to the Financial Stability Board (“FSB”) responding to IOSCO’s report on leverage (“IOSCO Leverage Report”), which sets forth “a proposed framework to help measure leverage used by investment funds that in some circumstances could pose financial […]

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Committee Submits Comment Letter to SEC Regarding the Proposed Rule Change to Establish a Corporate Bond New Issue Reference Data Service

On July 25, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding the proposed rule change filing by the Financial Industry Regulatory Authority, Inc. (“FINRA”). FINRA’s proposal would establish a new issue reference service for corporate bonds and charge associated fees (“Bond Data Service Proposal”). Under the Bond Data […]

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U.S. Treasury Report: Banks and Credit Unions – Two Year Progress Report

The U.S. Treasury Department’s report, A Financial System that Creates Economic Opportunities: Banks and Credit Unions released in June 2017, set forth reforms for the banking sector that would help ensure the stability of the financial system and spur economic growth. The Committee on Capital Markets Regulation (“the Committee”) has prepared a two-year progress report […]

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Committee Submits Comment Letter to SEC Regarding the Proposed Rule Change to Introduce a Liquidity Provider Protection Feature on Cboe EDGA Equities Exchange

On July 17, 2019, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding a proposed rule change filing by Cboe EDGA Exchange, Inc. (“EDGA” or the “Exchange”) with the SEC. The Exchange’s proposal would implement an asymmetric speed bump (i.e., one that applies an intentional delay to some order […]

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Enhancing the Regulatory Process for International Standard-Setting Bodies

International standard-setting bodies, specifically the Basel Committee on Banking Supervision, the Financial Stability Board, the International Association of Insurance Supervisors, and the International Organization of Securities Commissions, play a critical role in the regulation of the global financial system. These bodies develop regulatory standards on issues ranging from capital requirements for banking institutions to the […]

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Committee Submits Comment Letter to U.S. Banking Regulators Pertaining to Proposals for U.S. Operations of Foreign Banking Organizations

On June 11, 2019, the Committee submitted a comment letter to the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System and Federal Deposit Insurance Corporation on two recent proposals pertaining to foreign banking organizations (“FBOs”): (1) a Federal Reserve (the “Fed”) proposal that seeks to tailor the application […]

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Committee Staff Releases Update on Monetary Sanctions Imposed by U.S. Enforcement Agencies

On May 9, 2019, the Committee staff released an update on the monetary sanctions that U.S. public enforcement agencies with oversight of the U.S. financial system imposed during calendar 2018. This statement is intended to update the staff report released in June 2018, “Rationalizing Enforcement in the U.S. Financial System,” which reviewed the monetary sanctions […]

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Committee Submits Comment Letter to the Financial Stability Oversight Council on Proposed Interpretative Guidance on the Designation Process for Nonbank Financial Companies as Systemically Important

On April 25, 2019, the Committee submitted a comment letter to the Financial Stability Oversight Council (“FSOC”) to provide the Committee’s input on FSOC’s proposed interpretative guidance pertaining to its process for designating nonbank financial companies as systemically important. The Committee has previously commented extensively on the issue of FSOC’s designation of nonbank financial companies. […]

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Committee Report on Blockchain and Securities Clearing and Settlement

Blockchain technology has been touted for its potential to revolutionize many aspects of financial markets, including securities clearing and settlement systems. Stock exchanges in countries including Australia and Switzerland have announced plans to implement blockchain technology in securities trading over the next couple of years, while other jurisdictions (e.g. Singapore and Canada) have also studied […]

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