Committee Hosts Virtual Roundtable on IPOs and the Rise of SPACs

On April 27, 2022, the Committee hosted a Virtual Roundtable on “The Future of Going Public and Expanding Investor Opportunities: A Comparative Discussion on IPOs and the Rise of SPACs.” The roundtable vegan with Keynote Remarks from Commissioner Caroline Crenshaw of the U.S. Securities & Exchange Commission, followed by a panel discussion among subject matter […]

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Committee Submits Comment Letter on the SEC’s Private Funds Proposal

On April 25, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on private fund advisers (the “Proposed Rule”). The Proposed Rule includes a series of new rules and amendments under the Investment Advisers Act of 1940, as amended, applicable to investment advisers to private […]

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Committee Submits Comment Letter on the SEC’s Money Market Fund Proposal

On April 11, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on money market fund reforms. The Proposed Rule would make extensive changes to the rules governing money market funds (“MMFs”) under the Investment Company Act of 1940 (the “Act”), including by: (i) increasing […]

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Committee Submits Comment Letter on the SEC’s Security-based Swap Proposal

On March 21, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on the reporting of large security-based swap positions. The Committee’s letter proceeds in three parts. First, we describe the Proposed Rule’s reporting requirements, including a description of the credit default swaps and total […]

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Committee Submits Comment Letter on the SEC’s Securities Lending Proposal

On January 6, 2021, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on the reporting of securities loans. If adopted, the proposed rule would (i) require the reporting of certain terms of securities lending transactions to designated registered national securities associations (“RNSAs”), and (ii) require […]

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Assessing The Future of U.S. Listings By Chinese Companies: A Call For Structured Dialogue

The Committee on Capital Markets Regulation (the “Committee”) is concerned with the potential impact on U.S. capital markets from recent policy developments in China and the United States indicating that Chinese companies may halt future listings on U.S. stock exchanges and that Chinese companies presently listed on U.S. stock exchanges may be delisted or will […]

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Retail Investors and SPACs

The regulation of special purpose acquisition vehicles (“SPACs”) has received significant attention recently from both regulators and legislators. Although there are a number of policy issues involving SPACs, including disclosure requirements and securities law liability standards for the SPAC and its sponsors, much of the recent policy attention has been focused on the role of […]

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Staff Report on Revising the Framework for Non-Bank Emergency Lending

This staff report examines the Federal Reserve’s (the “Fed’s”) role in emergency lending to non-banks in light of its response to the COVID-19 pandemic and proposes a new framework for such lending.   Part I outlines the current framework governing emergency lending to non-banks, with a focus on the restrictions adopted in the Dodd-Frank Act following […]

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Committee Statement on the Administrative Procedure Act and Banking Supervision

In this statement, the Committee on Capital Markets Regulation (the “Committee”) reaffirms its long-standing position that the Administrative Procedure Act (the “APA”) fully applies to supervisory and regulatory actions by the U.S. Federal Reserve Board (the “Fed”). In particular, we review a forthcoming  law review article, Bank Supervision and Administrative Law, by former Federal Reserve Governor […]

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Committee Statement on Enhancing U.S. Equity Market Structure for Retail Investors

In this statement, the Committee on Capital Markets Regulation (the “Committee”) describes the regulation and functioning of U.S. equity market structure with a focus on retail investors, and it sets forth policy recommendations that would provide additional transparency for retail investors and enhance competition among broker-dealers and exchanges.   First, we consider whether the SEC […]

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