CCMR Comment Letter on Volcker covered funds proposal

On March 25, the Committee submitted a comment letter to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity Futures Trading Commission regarding their notice of proposed rulemaking to revise the regulations implementing Section […]

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Do More to Avert a Liquidity Crisis: Next steps for Congress, the Fed, the Treasury and the FDIC.

Originally Appeared in the Wall Street Journal The Federal Reserve, Treasury Department and banking regulators deserve congratulations for their bold, necessary actions to provide liquidity to the U.S. financial system amid the coronavirus crisis. But more remains to be done. We thus recommend: (1) immediate congressional action to expand the Federal Deposit Insurance Corp.’s authority […]

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Response to Covid-19 Crisis

The Committee’s President and Co-Chairs recommend three immediate actions to prevent a potential liquidity crisis: The Fed should create a commercial paper funding facility; Banking regulators should suspend liquidity requirements; Congress should restore the tools Dodd-Frank took away.   The statement can be found here.

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Dodd-Frank Worsens Covid’s Risk: The Fed, FDIC and Treasury need the same powers they wielded against the 2008 crisis.

Originally Appeared in the Wall Street Journal Coronavirus is contagious. So is financial panic. The spread of the novel coronavirus could cause a run on the financial system leading to a deep recession. Severe stock-market drops and increased demand for liquidity are warning signals. Bank equity capital has increased by $750 billion to $2.1 trillion […]

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Committee Submits Comment Letter on SEC’s Proposed Order Directing Self-Regulatory Organizations to Submit a New National Market System Plan for Equity Market Data

On February 28, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed order directing the relevant self-regulatory organizations, including the exchanges and FINRA, to submit a new national market system plan (a “Reg NMS plan”) for the dissemination of consolidated equity market data for NMS stocks (the […]

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Committee Submits Comment Letter to SEC Regarding the Proposed Rule Amending the “Accredited Investor” Definition

On January 31, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding the proposed rule to amend the definition of “accredited investor” under the Securities Act of 1933, as amended (the “Proposal”). The Proposal would amend the definition of “accredited investor” to, among other things: (i) add new categories […]

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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 […]

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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 […]

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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 […]

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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 […]

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