Nothing But The Facts: Asymmetric Speed Bumps in U.S. Equity Markets

A recent proposal by Cboe EDGA to implement an asymmetric speed bump on a U.S. stock exchange has faced criticism from a broad range of financial market participants, including asset managers, broker-dealers, trading firms, and financial market advocacy groups, as well as the Committee on Capital Markets Regulation (“the Committee”). In securities markets, a speed […]

Read More

Progress Update on Rationalizing Enforcement in the U.S. Financial System

In June 2018, the Committee on Capital Markets Regulation (the “Committee”) released a report, Rationalizing Enforcement in the U.S. Financial System (the “Enforcement Report”), which included nineteen recommendations for regulators to improve enforcement efforts for the U.S. financial system.   The recommendations fell under four broad categories: (i) enhancing the structure of the U.S. enforcement system […]

Read More

Committee Submits Second Comment Letter to SEC Regarding FINRA’s Amended Proposal to Establish a Corporate Bond Data Service

On October 22, the Committee submitted a second comment letter to the Securities and Exchange Commission (the “SEC”) regarding the amended proposal by the Financial Industry Regulatory Authority, Inc. (“FINRA”) to establish a new issue reference service for corporate bonds (the “Amended Bond Data Service Proposal”).   Under the original proposal, (i) FINRA sought to […]

Read More

Committee Submits Comment Letter to SEC Regarding the Concept Release on Harmonization of Securities Offering Exemptions

On September 19, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) on its concept release on harmonization of securities offering exemptions (the “Concept Release”). The Committee previously released a report in November 2018, Expanding Opportunities for Investors and Retirees: Private Equity (the “Private Equity Report”), which included a proposal […]

Read More

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 […]

Read More

The Financial Times Op-ed: Ordinary Savers Should Be Allowed to Invest in Private Equity

By Hal S. Scott Originally published by the Financial Times on August 27, 2019 Despite all the attention that is paid to the ups and downs of the big stock indices, private markets are where much of the action is. Last year, companies in the US received twice as much investment — $2.9tn — from […]

Read More

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 […]

Read More

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 […]

Read More

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 […]

Read More

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 […]

Read More