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SEC Investor Advisory Committee to Consider Recommendation on Tokenization of Equity Securities
On March 5, 2026, the Market Structure Subcommittee of the U.S. Securities and Exchange Commission’s (“SEC”) Investor Advisory Committee (“IAC”) released a recommendation regarding the tokenization of equity securities. The recommendation will be discussed and voted on at the IAC’s March 12, 2026 meeting....By: Mayer Brown Free Writings + Perspectives
Tokenization Guidance Useful to Debt and Derivatives Markets
Last week, the banking agencies issued guidance in the form of Frequently Asked Questions that provides certainty regarding the treatment of tokenized securities for purposes of the capital rules. While this is not surprising, it is helpful to market participants perhaps especially in the context of the repo and derivatives market as more market participants consider collateral in tokenized form....By: Mayer Brown Free Writings + Perspectives
OFAC 50 Percent Rule: Ownership Aggregation, SDN Risk, and Sanctions Compliance Strategy
Executive Summary: The OFAC 50 Percent Rule is a foundational doctrine of U.S. sanctions enforcement. It provides that any entity owned, directly or indirectly, 50 percent or more in the aggregate by one or more blocked persons is itself treated as a blocked person. Even if the entity does not appear on the SDN List....By: Friling Law
BCBS Consults On Consolidated Guidelines And Sound Practices For Banks And Supervisors
The Basel Committee on Banking Supervision (BCBS) has launched a consultation on a consolidated version of its guidelines and sound practices. This version seeks to reorganise existing guidance into a modular structure, replicating the BCBS's current format for the Basel framework. The guidelines are organised into 13 thematic modules, setting out expectations and practices on specific topics, each of which is divided into further chapters....By: A&O Shearman
Key Takeaways from the SEC's Revised Enforcement Manual
The Securities and Exchange Commission ("SEC") has revised its Enforcement Manual (the "Manual") for the first time since 2017, implementing critical changes to enforcement policies and procedures....By: Jones Day
EBA Opinion On EC Amendments To Draft RTS On "Equivalent Legal Mechanisms" Under CRR
The European Banking Authority (EBA) has published an opinion and related letter regarding the European Commission's (EC') proposed amendments to the final draft regulatory technical standards (RTS). These RTS specify what constitutes an equivalent legal mechanism to ensure that a residential property under construction is completed within a reasonable timeframe, for the purposes of risk-weighting requirements under the Capital Requirements Regulation (CRR)....By: A&O Shearman
Upcoming SEC Investor Advisory Committee on March 12
The Investor Advisory Committee (the “Committee”) of the Securities and Exchange Commission (the “SEC”) will hold a public meeting on March 12, 2026, beginning at 10:00 a.m. ET. The meeting will be open to the public and accessible via a live webcast on the SEC’s website....By: Mayer Brown Free Writings + Perspectives
Federal Banking Agencies Clarify Capital Treatment of Tokenized Securities
On March 5, the Federal Deposit Insurance Corporation (FDIC), Federal Reserve Board, and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) jointly issued FAQs clarifying how tokenized securities are treated under the federal regulatory capital rules....By: Troutman Pepper Locke
The Financial Services and Markets Act 2023 (Commencement No 13) Regulations 2026
The Financial Services and Markets Act 2023 (Commencement No 13) Regulations 2026 were made, following HM Treasury's policy response on applying the Financial Services and Markets Act 2000 model of regulation to the UK Capital Requirements Regulation. The regulations effect the revocation of Articles 4, 4A, 4B and 5 of the UK Capital Requirements Regulation (CRR) on 1 January 2027, by virtue of section 1(1) of, and Schedule 1 to, FSMA 2023....By: A&O Shearman
Upcoming SECURE 2.0 Amendment Deadline: Has Your Plan Been Amended?
The SECURE 2.0 Act of 2022 (SECURE 2.0) introduced many required and optional changes affecting defined contribution plans, including 401(k) plans, 403(b) plans, and employee stock ownership plans....By: Bradley Arant Boult Cummings LLP
Weekly Blockchain Blog - March 2026 #2
Major U.S. Payment Networks, Money Transfer Firms Launch Crypto Initiatives - This week, two major U.S. financial services companies that operate the world’s largest payment processing networks each announced initiatives designed to make payments with cryptocurrency easier and more accessible....By: BakerHostetler
Liability Management Exercises: Bandage or Bridge to Recovery?
Once an arcane corner of the capital markets, liability management exercises (LMEs) have become a mainstream restructuring tool. Of course, LMEs are not available to every borrower — the ability to execute one depends on loan documents that were deliberately drafted with this kind of flexibility......By: Ankura
FinCEN’s New Reporting Requirements: Essentials for Real Estate Professionals
The real estate industry faces a major regulatory shift with the implementation of the Financial Crimes Enforcement Network (FinCEN) Residential Real Estate Reporting Rule. Effective as of March 1, 2026, this rule imposes nationwide reporting requirements on certain residential real estate transactions—a significant expansion from prior geographic targeting measures....By: Foster Swift Collins & Smith
LLC Member Not Liable for LLC’s Debts and Usury
Under Limited Liability Company Law § 609(a), a member or manager of a limited liability company is not personally liable for the LLC’s debts, obligations, or liabilities solely by reason of being a member or acting in that capacity. Applying this rule, the courts in 27-21 27th St. Sponsors, LLC v. Kanta, 2026 N.Y. Slip Op. 01273 (1st Dept. Mar. 05, 2026), held that a minority member of an LLC could not be sued individually for the LLC’s obligations, as the operating agreement likewise...By: Freiberger Haber LLP
SEC Holds Roundtable on the “Retailization” of Private/Alternative Investments: A Hint of the Agency’s Direction
Last week, on March 4, 2026, the U.S. Securities and Exchange Commission (“SEC”) held a roundtable on retail investments in private market, or “alternative,” investments. Such investments might include, for example, hedge, credit, or other private funds, as well as non‑traded real estate investment trusts (REITs), business development companies (BDCs), a small but potentially growing number of mutual funds with “private tranches,” and publicly‑reporting registered closed‑end funds......By: Proskauer - Regulatory & Compliance
One Year In: US And Mexico Coordinate Sanctions Enforcement Against Cartel-Linked Timeshare Fraud Network
On February 19, 2026, almost exactly one year after the United States designated eight Latin America-based drug cartels as Foreign Terrorist Organizations (FTO) and Specially Designated Global Terrorists (SDGTs), the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the designation of five individuals and 19 entities for their participation in timeshare fraud schemes linked to Mexico’s Cartel de Jalisco Nueva Generacion (CJNG)....By: DLA Piper
FDIC publishes January 2026 enforcement actions
On February 27, the FDIC published its list of administrative enforcement actions issued in January. The agency reported eight orders, which included two consent orders, two orders terminating consent orders, two orders assessing civil money penalties, and two prohibition orders. The FDIC also reported that no administrative hearings were scheduled for the month of March....By: Orrick, Herrington & Sutcliffe LLP
UK PVDC Publishes Payments Forward Plan
The UK Payments Vision Delivery Committee (PVDC) has published the payments forward plan, outlining key initiatives expected across retail and wholesale payments and aspects of digital assets in the next three years. The plan sets out the actions required to deliver the government's National Payments Vision and support the continued growth of the sector. It focuses on initiatives led by HM Treasury, the Bank of England, the Financial Conduct Authority and the Payment Systems Regulator, while...By: A&O Shearman
OCC Proposed Rule Implementing the GENIUS Act: A Summary and Analysis
On February 25, 2026, the Office of the Comptroller of the Currency (OCC) released a much anticipated notice of proposed rulemaking (“Proposal”) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (“GENIUS Act”). The Proposal applies to the issuance of payment stablecoins and certain related activities by entities that are subject to the OCC’s jurisdiction. Comments on the Proposal are currently due May 1, 2026....By: Morrison & Foerster LLP
SEC and FINRA Enforcement Trends for Broker-Dealers: 2025-2026
In 2025, the US Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) experienced significant leadership changes, staffing departures, and a renewed “back to basics” emphasis on traditional retail investor fraud. This report analyzes key enforcement and examination developments affecting broker-dealers, explains what changed in 2025—including limited public enforcement metrics—and outlines what firms should anticipate from SEC and FINRA oversight in 2026...By: Morgan Lewis
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