Market Structure

Europe’s revised Markets in Financial Instruments Directive (MiFID II), effective  January 3, 2018, makes a number of important regulatory changes concerning the delivery of financial services and products. A number of these changes have an extraterritorial element that can have a significant impact on US firms. A particularly contentious area has been how European Union

In a decision issued on July 7, 2017, the U.S. Court of Appeals for the D.C. Circuit vacated revisions to the PJM Interconnection, L.L.C. (“PJM”) Minimum Offer Price Rule (“MOPR”) that had been proposed by the Federal Energy Regulatory Commission (“FERC”) in response to a filing submitted by PJM pursuant to section 205 of the

The staff of the SEC’s Office of Compliance Inspections and Examinations has announced its 2017 examination priorities.

In 2017, the SEC will focus on:

*Retail Investors—Protecting retail investors from product and service risks, roboadvisers and wrap fee programs

*Senior Investors and Retirement Investments—Focusing on variable insurance products, ETFs and target-date funds

*Market-Wide Risks—Focusing on

The SEC voted to publish for comment a proposal to create a single database that would allow regulators to track trading activity in the U.S. equity and options markets, referred to as a consolidated audit trail (“CAT”).  The CAT is being created by a joint plan of eighteen national securities exchanges and FINRA (collectively, the

The CFTC has proposed a set of rules, referred to collectively as proposed Regulation AT, that would, for the first time, impose risk control and other requirements governing algorithmic trading systems (ATSs) in futures contracts, options, and swaps traded on designated contract markets (DCMs) such as CME, CBOT, NYMEX, and ICE Futures US.  Regulation

On May 19, 2015, the Financial Stability Oversight Council (FSOC), established under the Dodd-Frank Wall Street Reform and Consumer Protection Act to oversee risks to the U.S. financial system, issued its Fifth Annual Report, highlighting the need for heightened risk management and supervisory attention in eleven different areas:

  • Cybersecurity
  • Changes in financial market structure

The May 19, 2015 Fifth Annual Report, issued by the Financial Stability Oversight Council (FSOC), established under the Dodd-Frank Wall Street Reform and Consumer Protection Act to oversee risks to the U.S. financial system, highlighted several issues relating to financial institution activities and regulations.

Increased risk taking in a low-yield environment

FSOC indicated its

The Fifth Annual Report issued May 19, 2015, by the Financial Stability Oversight Council (FSOC), established under the Dodd-Frank Wall Street Reform and Consumer Protection Act to oversee risks to the U.S. financial system. Themes discussed in the report included cybersecurity, market structure, reference rates and data collection.

Cybersecurity

The report highlights FSOC’s increasing concerns

The Equity Market Structure Advisory Committee of the Securities and Exchange Commission (SEC) will be holding its first meeting starting at 9:30 am Eastern Time on May 13, 2015 to discuss the impact of SEC Rule 611 of Regulation NMS — the SEC’s “order protection” or “trade-through” Rule — on US equity market structure.

The