Cadwalader attorneys reviewed the SEC's security-based swap rules under Dodd-Frank Title VII in light of the agency taking action to reopen the comment period on capital, margin and segregation requirements. Related cabinet coverage can be found here.
The memorandum reviews the particular questions raised in the SEC release reopening the comment period in addition to the various actions that the SEC has taken and is expected to take in the near future in order to implement security-based swap dealer regulation.
This memorandum was authored by Nihal Patel, Steven Lofchie, and Conor Almquist.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.