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US Regulatory Updates

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U.S. Congress

House Financial Services Committee Advances Bills

On 18 September, the U.S. House of Representatives Committee on Financial Services (“House Financial Services Committee”) held a markup and reported twelve bills favorably to the House floor. The bills were:

o   H.R. 123, the FHA Additional Credit Pilot Program Reauthorization Act, as amended, by a vote of 32-22. 

o   H.R. 132, the North American Development Bank Improvement Act, as amended, by a vote of 32-23. 

o   H.R. 4029, the Tribal Access to Homeless Assistance Act, as amended, by a voice vote. 

o   H.R. 4067, the Financial Inclusion in Banking Act of 2019, as amended, by a vote of 55-0. 

o   H.R. 4242, the Greater Accountability in Pay Act of 2019, as amended, by a vote of 32-21. 

o   H.R. 4300, the Fostering Stable Housing Opportunities Act of 2019, as amended, by a vote of 47-0. 

o   H.R. 4302, the Homeless Assistance Act of 2019, as amended, by a vote of 49-0. 

o   H.R. 4328, the Protecting Innocent Consumers Affected by a Shutdown Act, as amended, by a vote of 32-22. 

o   H.R. 4329, the ESG Disclosure Simplification Act of 2019, as amended, by a vote of 31-22. 

o   H.R. 4344, the Investor Protection and Capital Markets Fairness Act, as amended, by a vote of 49-5 

o   H.R. 4335, the 8-K Trading Gap Act of 2019, as amended, by a vote of 52-0. 

House Passes Short-Term Spending Bill

On 19 September, the U.S. House of Representatives (“House”) passed H.R. 4378, the “Continuing Appropriations Act, 2020, and Health Extenders Act of 2019,” by a vote of 301-123. The continuing resolution temporarily funds the federal government until November 21, 2019. Additionally, the bill continues the Export-Import Bank of the United States, the National Flood Insurance Program, and several smaller health and immigration programs. Lastly, the bill allows for additional payments to farmers affected by tariffs through the Commodity Credit Corporation. The U.S. Senate plans to consider the legislation this week.

House Passes Financial Services Bills 

On 19 and 20 September, the House passed four financial services bills by voice vote. The bills were: 

·        H.R. 3625, the PCAOB Whistleblower Protection Act of 2019. 

·        H.R. 3619, the Appraisal Reform Act of 2019. 

·        H.R. 2613, the Advancing Innovation to Assist Law Enforcement Act. 

·        H.R. 2290, the Shutdown Guidance for Financial Institutions Act. 

SEC & CFTC

SEC and CFTC Issue Update to June 2019 Joint CFTC-SEC-FCA Statement

On 19 September, the SEC and Commodity Futures Trading Commission (“CFTC”) issued an update to its 24 June joint statement of those agencies and the U.K. Financial Conduct Authority (“FCA”).  The 24 June statement discussed “opportunistic strategies in the credit derivatives markets” and “outlined mutual concerns about the pursuit of these strategies and the adverse impact they may have on the integrity, confidence and reputation of the credit derivatives markets, as well as markets more generally.”  The 19 September statement supports the proposed protocol from the International Swaps and Derivatives Associations (“ISDA”). ISDA’s protocol contains two amendments to the 2014 ISDA Credit Derivatives Definitions. The first relates “to the Failure to Pay definition and the other to the Outstanding Principal Balance definition.” Although the latest statement offers support, it notes not that “the proposed ISDA protocol will not address many of the concerns identified in the Joint Statement, such as opportunistic strategies that do not involve narrowly tailored credit events.”

SEC & Securities

SEC Commissioner Peirce Emphasizes Importance of Cross-Border Regulatory Harmonization

On 13 September, SEC Commissioner Hester Peirce emphasized the importance of regulatory harmonization in the agency’s cross-border swap regime in an address at the Eurofi Financial Forum in Helsinki, Finland. Peirce argued that an SEC regulatory regime for security-based swaps should recognize the approach to derivatives regulation taken by foreign regulators. She advocated “an approach to substituted compliance respects both our different approaches and shared objectives." Further, she said that these “[d]eterminations will not be based on rule-by-rule assessments of foreign regimes, but on a broader look at the alternative regulatory regime.” Peirce also advised that comparability determinations will take time, and she urged non-U.S. regulators to reach out as soon as possible to get the conversations started.

 

SEC Proposes Rules to Update Statistical Disclosures for Banking Registrants

On 17 September, the SEC announced that it has proposed rules to (i) update the statistical disclosures that bank and savings and loan registrants provide to investors and (ii) eliminate disclosures that overlap with Commission rules, U.S. Generally Accepted Accounting Principles or International Financial Reporting Standards. The proposed rules would replace Industry Guide 3, Statistical Disclosure by Bank Holding Companies, with updated disclosure in a new subpart of Regulation S-K. The Commission’s proposed rules would require disclosure about the following: (i) distribution of assets, liabilities and stockholders’ equity, the related interest income and expense, and interest rates and interest differential; (ii) weighted average yield of investments in debt securities by maturity; (iii) maturity analysis of the loan portfolio including the amounts that have predetermined interest rates and floating or adjustable interest rates; (iv) an allocation of the allowance for credit losses and certain credit ratios; and (v) information about bank deposits including amounts that are uninsured.

SEC Adopts Amendments to the Volcker Rule

On 18 September, the SEC joined the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corp. (“FDIC”), and the CFTC in adopting amendments to the rules under section 13 of the Bank Holding Company Act, commonly known as the “Volcker Rule.” The latest amendments to the Volcker Rule cover a number of topics, including: (i) compliance program requirements and thresholds; (ii) proprietary trading; and (iii) covered funds. On 20 August, the FDIC published a fact sheet regarding the final rule amendments. The Federal Reserve (“Fed”) has yet to approve the revisions.

o   SEC Chairman Jay Clayton released a public statement supporting the significant revisions. Clayton stated, “The amendments the Commission has adopted today draw on the Volcker Rule agencies’ collective experience in implementing the rule and overseeing compliance in our complex marketplace over a number of years.  These amendments further the Volcker Rule’s statutory objectives, while simplifying, clarifying and better tailoring the application of the rule.”

o   Commissioner Allison Herren Lee disagreed with the Volcker Rule amendments, stating, “[w]e have reduced the rule’s scope and weakened compliance requirements ostensibly in the name of simplicity and clarity.” Further, Lee argued, “The rule amendment significantly increases the risk that large banks will move, by inches and degrees, back toward business as usual—where proprietary trading is intermixed with the other activities large banks undertake to put their massive balance sheets to work, while regulators struggle to keep up.”

o   Commissioner Robert J. Jackson, Jr. also dissented from the SEC’s decision, stating, “[r]olling back the Volcker Rule while failing to address pay practices that allow bankers to profit from proprietary trading puts American investors, taxpayers, and markets at risk.” Jackson also contended that “[t]he facts offer little support for the belief behind this release – that the Volcker Rule reduces liquidity.”

SEC Adopts New Rules and Amendments under Title VII of Dodd-Frank

On 19 September, the SEC announced that it took a significant step toward establishing the regulatory regime for security-based swap dealers by adopting a package of rules and rule amendments under Title VII of the Dodd-Frank Act. These actions establish recordkeeping and reporting requirements for security-based swap dealers and major security-based swap participants and amend the recordkeeping and reporting requirements for broker-dealers. Under these rules, these companies will be required to create and retain fundamental business records to document and track their operations, facilitating the Commission's ability to monitor compliance and reducing risk to the market.

SEC Commissioner Roisman Calls for Reassessment of Equity Market Structure

On 19 September, SEC Commissioner Elad Roisman called for a broad reassessment of equity market structure regulation in a speech at the SIFMA Equity Market Structure Conference in New York. Roisman reviewed the impact of Regulation NMS since its adoption in 2005. Roisman suggested that the SEC reconsider the regulatory requirements for best execution, stating, “I think investors, our markets, and the industry as a whole would benefit from this Commission saying more on broker best execution, especially if the current lack of guidance may hinder the ability of firms to satisfy best execution in a flexible, practical, and principles-based manner.” Regarding the Order Protection Rule (“OPR”), he argued that the rule forces brokers “to connect to, purchase market data from, and take into account prices on all exchanges.” He questioned whether OPR as it exists today is best for investors and exchanges and stated that it might may be time to reexamine the fifteen-year-old rule. He also urged reassessment on order management systems (“OMSs”) and questioned whether OMSs’ consolidation of several services raises “new risks to investors or our markets that our existing regulations were intended to address.” Lastly, Roisman suggested a review of ‘finders’ – “[t]hose who help small businesses, seeking to raise capital, identify and locate potential investors (typically for a fee).” Roisman noted, “Finders can play an important role in filling the gap to help small businesses obtain early stage financing. But the regulatory framework that governs them has been ambiguous at best.”

CFTC & Derivatives

CFTC Approves Amendment to Volcker Rule

On 14 September, the CFTC approved 3-2 via seriatim the final rule on “revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds.” -- i.e., amendments to the Volcker Rule

o   On 16 September, CFTC Chairman Heath Tarbert spoke about his approval of the revisions to the Volcker Rule.  Tarbert stated that “the rule has become overly complex and hard to understand; at this point it is also nearly unadministrable.” He noted the regulations “create confusion over what is acceptable activity for banking entities.” Tarbert expressed concern that the Volcker Rule may “affect liquidity in the derivatives markets,” which can “negatively impact the ability of agricultural, energy, manufacturing, and other companies in the real economy to engage in risk mitigation activities.” He stated the amended regulations will help simplify the Volcker Rule and “lessen the burden on smaller regional banks and benefit end users of derivatives.”

o   On 16 September, Chairman Tarbert and CFTC Commissioner Brian Quintenz issued a statement supporting the interagency amendments to the Volcker Rule. They stated that the amendments “simplify the rule’s application; provide objective, clear standards for prohibited and permissible activities; and tailor the rule’s requirements to focus on entities with the most significant trading activity.” The statement also highlighted the need for continued interagency work, specifically surrounding the standardized approach for counterparty credit risk (“SA-CCR”)  proposed by banking regulators which they believe could “have a profoundly negative impact on the derivatives market generally, and particularly on America’s energy producers and consumers – including farmers, ranchers, processors, manufacturers, retailers, and any business that relies on the transportation of physical goods.” To address this, the two stated that the SA-CCR should be “revisited to ensure that they are appropriately calibrated to the actual risks of the underlying commodity and the maturity of the derivatives contract.”

o   On 16 September,  CFTC Commissioner Rostin Behnam issued a statement dissenting to the Commission’s decision to approve revisions to the Volcker Rule. Behnam stated his concern that “our action would encourage a return to the risky activities that led to the financial crisis, and perhaps further consolidate trading activity into a few institutions.” Specifically, he said that the rule “significantly weakens the prohibition on proprietary trading by narrowing the scope of financial instruments subject to the Volcker Rule.”

CFTC Holds Open Commission Meeting

On 16 September, the CFTC held an open meeting to consider final rules on “position limits and position accountability for security futures products (“SFP”)” and a proposed rule on “public rulemaking procedures.” The CTFC unanimously approved both measures.

16 September, the CFTC held an open meeting to consider a final rule on “position limits and position accountability for security futures products (“SFP”)” and a proposed rule on “public rulemaking procedures.” The CTFC unanimously approved both measures.

o   In his opening statement for the meeting, Commissioner Quintenz spoke about his support for both rules as examples of “good government.” Quintenz stated that the SFP rule would provide “overdue updates to SFP position limits” and “provide regulatory comparability with equity options and minimize competitive disparity between the two markets.”

o   Commissioner Rostin Behnam issued a statement concurring with the CFTC’s proposed rule on public rulemaking procedures. Behnam stated he supported the rule’s aim to “succinctly and unambiguously confirm that the Commission’s rulemaking process is governed by the Administrative Procedure Act.” 

o   CFTC Commissioner Dawn Stump issued a statement supporting both of the rulemakings. Stump said that the SFP rule will “make our position limit rules for SFPs more consistent with our rules for other futures contracts, adjust the time during which position limits must be in effect, and enhance Exchange discretion in administering position limits for SFPs in certain respects.”

o   CFTC Commissioner Dan Berkovitz issued two statements regarding the Commission’s rules. The first statement expressed his support of the rule to amend the Commission’s position limit requirements for SFPs. He said that this rule “more closely aligns the SFP limits with the Commission’s historical practice of considering deliverable supply in setting spot month limits for physical delivery contracts,” and will “help to level the regulatory playing field between SFPs and equity options.” Berkovitz’s second statement was a concurrence on the proposed rulemaking to amend the rulemaking process. He emphasized the importance of the government to “serve the people by being transparent about the procedures we use to make our rulemaking process transparent” and suggested “adding a web page to the CFTC’s web site that explains in plain language the Commission’s rulemaking process and how stakeholders and the general public can play an important role through the statutorily mandated notice and comment process.”

CFTC Director of Enforcement James McDonald Makes Remarks at CFTC-DOJ Press Conference

On 16 September, the CFTC filed manipulation and spoofing charges against three individuals who served as “executives and traders on the same trading desk of a major U.S. financial institution.”  In connection with the filing of the charges, CFTC Director of Enforcement James McDonald highlighted four important innovations aimed at combatting fraud moving forward.  First, the CFTC has created the Spoofing Task Force to “serve as a coordinated effort across the Division of Enforcement – with members in each of our offices – to root out manipulation and spoofing from our markets.”  Second, the Division of Enforcement has “enhanced our ability to detect misconduct through the use of data analysis” which allows the CFTC to “identify, in the trading data, forms of misconduct in ways that complement our understanding of the activity through our other enforcement tools.”  Third, the CFTC has “worked to develop our cooperation program for individuals who have committed misconduct but wish to cooperate with us in our investigations.” Lastly, the CFTC has “strengthened our relationship with the Department of Justice and the Federal Bureau of Investigation,” as “a robust combination of criminal prosecution and regulatory enforcement is essential to achieving our goals of preserving market integrity and protecting our market participants.”

Chairman Tarbert Announces Executive Leadership Appointment

On 17 September, CFTC Chairman Tarbert announced the executive leadership appointment of Dorothy DeWitt to serve as Director of the Division of Market Oversight.

CFTC Announces Technology Advisory Committee Meeting

On 18 September, the CFTC announced that its Technology Advisory Committee (“TAC”) will hold an open meeting on 3 October. At the meeting, the TAC “will hear presentations and actionable recommendations from the TAC subcommittees on Automated and Modern Trading Markets, Distributed Ledger Technology and Market Infrastructure, Virtual Currencies, and Cybersecurity.”

Commissioner Stump Makes Keynote Address at 2019 Annual Europe Conference

On 19 September, Commissioner Stump delivered a keynote address at the ISDA’s Annual Europe Conference. Stump spoke about the importance of joining forces with fellow regulators, as “a strong global alliance is essential to achieving our shared pursuit of well-functioning derivatives markets.” Stump discussed the need for “trust and deference” in the mission to “regulate and supervise cross-border central counterparties” (“CCPs”) because “a duplicative, confusing web of multiple regulatory agencies around the world asserting overlapping but jurisdictionally distinct regulation and supervision of global CCPs would undermine, not enhance, the safety of our clearing system.”  Stump also addressed swap data reporting, stating that “the lack of global harmonization in swap data reporting continues to hinder implementation of post-crisis reforms, and divergent requirements across jurisdictions are an ongoing and substantial burden on market participants.” Lastly, Stump addressed recent measures addressing the application of initial margin (“IM”) for non-centrally cleared derivatives. Stump stated that “firms need to adopt the methodology to calculate IM requirements and acquire the necessary infrastructure.”

Bank Regulators

FDIC Board Holds Meeting

On 17 September, the FDIC held a board meeting in which the Board of Directors approved a final rule regarding capital simplification for qualifying community banking organizations and approved a proposed rule and request for comment regarding margin and capital requirements for covered swap entities.

o   Capital Simplification: The final rule aims to simplify the regulatory capital requirements for community banking organizations by allowing qualifying community banking organizations that have “less than $10 billion in total consolidated assets and meet other qualifying criteria, including a leverage ratio … of greater than 9 percent” to opt into a community bank leverage ratio (“CBLR”) framework, which will allow such organizations to be “considered to have satisfied the generally applicable risk-based and leverage capital requirements in the agencies’ capital rules.” In particular, the final rule deviated from the proposed rule in that the final rule: (i) adopted the existing definition of tier 1 (“tier 1 capital divided by average total consolidated assets”) in the numerator of the community bank leverage ratio as opposed to the proposed definition of tier 1 (“the ratio of tangible equity to average total consolidated assets”); and (ii) replaced the prompt corrective action framework with a framework that “allow[s] a banking organization that elects to use the community bank leverage ratio framework to be considered well-capitalized during the two-quarter grace period if its leverage ratio is 9 percent or less and greater than 8 percent.” The final rule will now be issued on an interagency basis with the OCC) and the Federal Reserve (“Fed”) with an effective date of 1 January 2020.

o   Margin and Capital Requirements: The proposed rule jointly issued by the OCC, Fed, FDIC, Farm Credit Administration (FCA”), and the Federal Housing Finance Agency (“FHFA”) would “amend the agencies’ regulations, known as the Swap Margin Rule, that require swap dealers and security-based swap dealers under the agencies’ respective jurisdictions to exchange margin with their counterparties for swaps that are not centrally cleared.” The Swap Margin Rule establishes minimum margin and capital requirements for swap entities that are prudentially regulated by the OCC, Fed, FDIC, FCA, or FHFA, and apply to swaps that are not cleared by a registered derivatives clearing organization or a registered clearing agency (“non-cleared swaps”). The Swap Margin Rule currently applies only to non-cleared swaps entered into on or after the applicable compliance date of the rule to a specific swap entity. Non-cleared swaps entered into prior to the swap entity’s compliance date, known as legacy swaps, would generally not be subject to the rule’s requirements. In order to allow a smooth transition away from LIBOR to other benchmarks and to ensure that legacy swaps that are amended because of this transition retain their legacy status, the proposed rule would, among other things, “permit swaps entered into prior to an applicable compliance date (legacy swaps) to retain their legacy status in the event that they are amended to replace an interbank offered rate (IBOR) or other discontinued rate.” The comment period closes 30 days after publication of the proposed rule in the Federal Register.

Fed Issues FOMC Statement

On 18 September, the Fed issued a statement of its Federal Open Market Committee’s (“FOMC”) decisions regarding monetary policy implementation. In the statement, the FOMC said that “[i]n light of the implications of global developments for the economic outlook as well as muted inflation pressures,” the FOMC has decided to lower the target range for the federal funds rate by 25 basis points from 2 to 2-1/4 percent to 1-3/4 to 2 percent. In addition, the Fed voted unanimously to lower the interest rate paid on required and excess reserve balances from 2.10 to 1.80 percent, effective September 19, 2019. Lastly, the Fed unanimously voted to approve a quarter percentage point decrease in the primary credit rate from 2.75 to 2.50 percent, effective August 1, 2019. In conjunction with its statement, the FOMC also released its economic projections and the target federal funds rate projections made by FOMC participants.

o   On 20 September, James Bullard, President and CEO of Federal Reserve Bank of St. Louis, published a blog arguing that the Fed should have lowered the federal funds rates by 50 basis points to 1-1/2 to 1-3/4 percent. He noted that there are “signs that U.S. economic growth is expected to slow in the near horizon” and that “[t]rade policy uncertainty remains elevated, U.S. manufacturing already appears in recession, and many estimates of recession probabilities have risen from low to moderate levels.” Additionally, he noted that the U.S bond “yield curve is inverted, and our policy rate remains above government bond yields for nearly every country in the G-7.”

o   On 20 September, Eric Rosengren, President and CEO of Federal Reserve Bank of Boston, issued a statement arguing that the Fed should not have lowered the federal funds rates. He noted that “[a]dditional monetary stimulus is not needed for an economy where labor markets are already tight, and risks further inflating the prices of risky assets and encouraging households and firms to take on too much leverage.”

CFPB

Trump Administration Asks Supreme Court to Accept Appeal of Case Questioning Constitutionality of CFPB Structure

On 17 September, the Department of Justice (“DOJ”) filed with the U.S. Supreme Court a brief urging it to hear the appeal in a case centered on whether the Consumer Financial Protection Bureau’s (“CFPB”) structure is constitutional. The DOJ’s brief argues that the CFPB was established by the Dodd-Frank Act in violation of the Constitution’s separation of powers because the statute allows the president to remove the director of the CFPB only for “inefficiency, neglect of duty, or malfeasance in office.”

o   On 17 September, CFPB Director Kathy Kraninger sent to Senator Mitch McConnell (R-KY) and Congresswoman Nancy Pelosi (D-CA) a letter in which Kraninger notified the lawmakers that she agrees with the position taken by the DOJ in its brief filed with the Supreme Court.  

CFPB Announces Continued Publication of Consumer Complaints

On 18 September, the CFPB announced that it will continue the publication of consumer complaints, data fields, and narrative descriptions through the Bureau’s Consumer Complaint Database. The CFPB also said it would make several enhancements to the information available to users of the database, including: ”modified disclaimers to provide better context to the published data; integrating financial information and resources into the complaint process to help address questions and better inform consumers before they submit a complaint; and information to assist consumers who wish to contact the financial company to get answers to their specific questions.”

o   On 18 September, CFPB Director Kraninger delivered remarks regarding the database at the National Consumer Empowerment Conference. She said that the Consumer Complaint Database “has not been without controversy on the part of both consumer advocates and industry” regarding whether the database should remain public. She then explained that the “database is here to stay” and that “the Bureau will continue to publish all previously disclosed fields,” but that the functionality of the database will be greatly improved.     

CFPB Director Kraninger Speaks at CFPB Symposium on Behavioral Economics

On 19 September, CFPB Director Kraninger spoke at the CFPB’s symposium on “Behavioral Economics and Consumer Financial Services Policy.” She kicked off the symposium by noting that the symposium was part of a “broader symposia series that seeks to gather experts in a variety of different fields to tackle legal and policy issues facing the Bureau,” including topics such as “abusive acts or practices”, “various issues the Bureau must deal with when interpreting statutes,” and “the broader issue of how the Bureau approaches consumer protections policy in general.” Kraninger then made some observations on how the Bureau sets its consumer protection policies, stating: “Most fundamentally, the Bureau is guided by the objectives Congress set forth in our statute: ensuring that all consumers have access to the markets for consumer financial products and services that are fair, transparent, and competitive. So, in its rulemaking, the Bureau seeks, consistent with its legal authorities, to articulate clear rules of the road for regulated entities that promote competition, increase transparency, and preserve fair markets for consumer financial products and services.”       

 

CFPB and FTC to Host December Workshop on Accuracy in Consumer Reporting

On 19 September, the CFPB and Federal Trade Commission (“FTC”) announced they will host a public workshop on 10 December 2019 to discuss issues affecting the accuracy of both traditional credit reports and employment and tenant background screening reports. According to the agencies’ press release: “The December workshop seeks to bring together stakeholders – including industry representatives, consumer advocates, and regulators – for a wide-ranging public discussion on the many issues impacting the accuracy of consumer reports. The agencies invite interested individuals to submit comments recommending topics that should be addressed or specific information on” the many topics listed in the press release.     

UPCOMING EVENTS 

o   September 23: Comments are due on the CFTC’s “Notice of Intent to Renew Collection 3038-0017, Market Surveys.”

o   September 23: Comments are due on the CFTC’s “Notice of Intent to Renew Collection 3038-0107, Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery.”

o   September 23: Comments are due on the CFTC’s “Notice of Intent to Renew Collection 3038-0031, Procurement Contracts.”

o   September 24: Comments are due on the CFTC’s “Notice of Intent to Renew Collection 3038-0067, Protection of Consumer Information Under the Fair Credit Reporting Act.”

o   September 24: The CFTC’s Global Markets Advisory Committee will meet.

o   September 24: The House Financial Services Committee will hold a hearing entitled “Oversight of the Securities and Exchange Commission: Wall Street’s Cop on the Beat.”

o   September 25: The House Financial Services Committee’s Subcommittee on Consumer Protection and Financial Institutions will hold a hearing entitled “Promoting Financial Stability: Assessing Threats to the U.S. Financial System.”

o   September 25: The SEC will hold an open meeting to discuss: (i) publication or submission of quotations without specified information; (ii) solicitations of interest prior to a registered public offering; (iii)  creation of new ETFs; and (iv) an order granting a conditional exemption from compliance with certain provisions of the Securities Exchange Act of 1934 for certain ETFs.

o   September 25: The U.S. Senate Committee on Banking, Housing, and Urban Affairs will hold a hearing entitled “Facilitating Faster Payments in the U.S.”

o   September 25: Comments are due on the FDIC’s rule proposal to rescind and remove the deposits regulations.

o   September 26: Fed Vice Chair Richard H. Clarida will deliver a speech on the Fed’s review of its monetary policy strategy, tools, and communication practices.

o   September 26: The House Financial Services Committee’s Task Force on Financial Technology will hold a hearing entitled “The Future of Real-Time Payments.”

o   September 26: The SEC will hold a closed meeting to discuss: (i) institution and settlement of injunctive actions; (ii) institution and settlement of administrative proceedings; (iii) resolution of litigation claims; and (iv) other matters relating to enforcement proceedings.

o   September 26: LabCFTC will host Office Hours at Georgia Tech in Atlanta, Georgia.

o   September 26: CFTC Commissioner Berkovitz will give the keynote address at the 2019 ISDA Annual North America Conference.

o   September 27: Fed Vice Chair for Supervision Randal Quarles will deliver speech on macroprudential regulation.

o   September 30: This is the compliance date for adopted SEC rules that increase information brokers must provide to investors on order handling.

Ianthe Zabel
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