This commentary reviews the provisions of the Dodd-Frank
Wall Street Reform and Consumer Protection Act that are pertinent to the
insurance industry and opines on what those provisions portend for the
regulation of the insurance industry in the future.
On July 21, 2010, President Obama signed...
Passage of the landmark Dodd-Frank Act, the most
far-reaching financial regulatory legislation since the Great Depression, has
set the stage for major adjustments in the financial services industry. In a
second Roundtable discussion, Arnold & Porter attorneys discuss the Act's
impact on executive...
Passage of the landmark Dodd-Frank Wall Street Reform and
Consumer Protection Act, the most far-reaching financial regulatory legislation
since the Great Depression, has set the stage for major adjustments in the
financial services industry. The Act impacts regulation, supervision, and in
On Monday, March 15,
2010, Senate Banking Committee Chairman Chris Dodd (D-CT) released a Chairman's
Mark of the "Restoring American Financial Stability Act of 2010" (the
"Bill"). The Bill, which has been in development for months, is
intended to replace the Discussion...
On May 20, 2010, the
Senate passed the "Restoring American Financial Stability Act of
2010" as amended ("Senate Bill"). Congressional leadership has
indicated that conference committee proceedings will take place in June, making
it likely that the legislation will be passed by the...
by Dan Crowley, Karishma Shah Page, Bruce Heiman, Collins
R. Clark and Justin D. Holman
On December 11, the
House of Representatives passed H.R. 4173, the Wall Street Reform and Consumer
Protection Act of 2009 (see H.R. 4173 as introduced), by a vote of 223 to 203.
On June 30, 2010,
the House adopted the conference report on H.R. 4173, the Dodd-Frank Wall
Street Reform and Consumer Protection Act ("Dodd-Frank Bill" or
"Bill"). The Senate is expected to follow suit when it returns from
recess later in July. This alert provides a high...
Many of the provisions in the Dodd-Frank Wall Street Reform and Consumer Protection Act
merely provide for future regulatory framework. That it is in part true for the
changing definition of "accredited investor" under the Securities Act. The
other part is that the definition changed once...
The Dodd-Frank Act contemplates the creation of a new
Consumer Financial Protection Bureau (CFPB) within the Federal Reserve. CFPB
would be responsible for consumer protection over financial products and
services offered by both banks and nonbanks, including mortgage lenders,
captive finance companies...
Hedge funds were a key subject of debate during the passage of Dodd-Frank. While the funds were not tied to the causes of the market crisis, they do represent large pools of assets which can impact the market. Regulators frequently note that they have inadequate information about the funds. Accordingly...
In many instances, the Dodd-Frank Wall Street Reform and Consumer Protection Act
merely set a framework for financial reform and left much of the heavy lifting
to the financial regulatory agencies. The SEC published their agenda for the implementation of Dodd-Frank .
It is a long list. Compliance...
by Robert J. Pile and Heather J. Howdeshell
TCF National Bank (TCF) has filed a suit in the United
States District Court in South Dakota challenging the constitutionality of
Section 1075 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(known as the Durbin Amendment). The Durbin Amendment...
You may have seen May 2, 2011 Wall Street Journal
article entitled "Overhaul Grows and Slow" ( here ),
which described the backlog developing as regulators struggle to meet the
rule-making guidelines mandated by the Dodd-Frank Act. The article itself was
interesting enough, but if you really...
by Edmund D. Harllee
On Monday, May 23, the Federal Reserve Board (the
"Board") issued proposed revisions to its Regulation E (Electronic Fund
Transfers) in order to implement changes required by the Dodd-Frank Wall Street
Reform and Consumer Protection Act (the "Act").
The SEC announced yesterday that it will be holding an
open meeting on June 22, 2011, evidently to discuss new proposed
changes to the new Advisers Act rules pending under Dodd Frank. For fund
managers concerned about becoming subjected to Advisers Act registration once
Dodd-Frank becomes effective...
Contingency Planning in the Absence of a
memorandum first explains the July 16, 2011 problem that will arise because the
Dodd-Frank derivatives legislation (Title VII of the statute) goes into effect
without either a ready regulatory plan or an operating market structure....
by: Edmund D. Harllee
On Monday, June 20, 2011, the Board of Governors of the Federal Reserve System
(the "Board") issued final rules modifying the Official Staff Commentary to its
Regulation Z (Truth In Lending) and Regulation M (Consumer Leasing) to
implement certain of the requirements...
The Dodd-Frank Wall Street Reform and Consumer Protection
Act represents the most comprehensive financial regulatory reform measures
taken since the great depression. So, one year after enactment, what do we
By the time you read this, we will have commemorated the
first anniversary of the passage...
The SEC has now finalized the rules implementing
the Investment Advisers Act of 1940 (the " Advisers Act ") changes,
which had been issued in proposed form near the end of 2010 following
passage of the Dodd-Frank Act earlier that summer. These rules went
into effect July 21, 2011. Fund...
This is the first post in a series exploring
the recent SEC regulations which define the term "venture capital fund" for the
purposes of determining whether a fund's manager is exempt from SEC
registration requirements under Dodd-Frank.
The Dodd-Frank Act excluded from its registration...
You would expect that a publication with a libertarian
tilt like The Economist would not look favorably at the Dodd-Frank
Wall Street Reform and Consumer Protection Act . They call it Too big not to fail . Being The
Economist , the article argues with the facts on its side.
by Andrew L. Weil , Alexander G. Fraser , and Bradley E. Phipps
The Dodd-Frank Act – signed by President Barack Obama more than three years ago, and since then advanced with a host of rules and regulations – has been widely viewed as a law that addresses systemic risk in the financial...