Financial Services Update______June 20, 2011
Volume 6, No. 23



IN THIS ISSUE

Insights from Winston & Strawn

In the News

Banking Agency Developments

Treasury Department Developments

Commodity Futures Trading Commission

Securities and Exchange Commission

Exchanges and Self-Regulatory Organizations

Judicial Opinions

Rules Effective Dates

Winston & Strawn Speaking Engagements and Publications


Insights from Winston & Strawn [Top]

On Thursday, June 16, 2011, Barry Zubrow, the Chief Risk Officer of JP Morgan Chase, testified before the House Financial Services Committee, putting some "meat on the bones" of last week's well-reported comment of JP Morgan Chase's Chief Executive Officer Jamie Dimon. Dimon had publicly suggested to Federal Reserve Chairman Ben Bernanke that the cumulative effect of hundreds of impending bank regulations may retard an economic recovery.
Mr. Zubrow began by noting that, in the last eight years, the market share that U.S. banks held among the 50 largest global banks has dropped from 50 percent to 24 percent.
He acknowledged that most of the post-crisis reforms, such as applying capital requirements to non-bank, systemically significant firms (SIFIs) to limit leverage and regulating all originators of mortgages, will improve soundness without harming competitiveness. Had these changes been in place before the crisis, as well as required risk retention in securitization, merger of the Office of Thrift Supervision into the Office of the Comptroller of the Currency, and the imposition of supervision and reporting requirements on derivatives market participants and central clearing of most derivatives trades, Lehman Brothers would have been regulated and supervised like banks; AIG would have had to register as a major swap participant, report, and be subject to federal supervision; Countrywide and Washington Mutual would have been required to retain the risk of subprime mortgages they originated; and Washington Mutual would have been subject to national bank mortgage underwriting standards.
However, he also suggested that U. S. policymakers should focus on how much the proposed regulations collectively reduce risk-taking that is essential to funding business growth, while other countries reject or defer such regulations. The Volcker Rule has been rejected by other countries; our proposed margin requirement rule for derivatives is an outlier; U.S. rules, unlike those in the EU or Asia, require affiliates to post margin for derivatives trades within a banking group; and our stress tests are more stringent than those of any other country.
The concern here is multi-fold. First, on top of impending Basel III capital increases, which would correspond to increasing Tier 1 common equity, from a minimum of 4 percent (6 percent to be well-capitalized) of risk-weighted assets to more than 10 percent under the capital rules currently applicable, SIFIs and banking organizations with more than $50 billion in consolidated assets, under the Dodd-Frank Act, are to be subjected to more stringent capital standards, a so-called "SIFI surcharge," which a Federal Reserve Governor suggested last week could result in a 14 percent capital requirement. Second, the testimony noted that examiner supervision has increased. Third, the Dodd-Frank Act requires U. S. banks to push out derivatives activities into separately capitalized subsidiaries, thus depriving banks of a favorable cost of funding, a requirement not adopted by any other country and one opposed by each of the federal bank regulators. Fourth, a proposed requirement that all non-financial end-users of swaps should negotiate credit support arrangements with their swap dealers threatens margin requirements on the hedging activities of thousands of Main Street American companies, potentially inhibiting job creation.
Mr. Zubrow's testimony did not touch on a number of other aspects of the Dodd-Frank Act and its implementing regulations that some have suggested may adversely impact economic growth, such as the effect that proposed 20 percent down payment "Qualified Residential Mortgages" with low debt-to-income ratios exempt from risk retention requirements may have on recovery of the housing market, or the effect of a Durbin Amendment-triggered loss of an estimated $12 billion in annual revenue ($8 billion in annual after-tax earnings), will have on the banking industry's ability to build common equity capital. Mr. Dimon had asked Chairman Bernanke whether anyone had studied the cumulative economic effect of these regulations, and the Chairman responded that nobody had conducted a comprehensive analysis of the impact of all of this on credit, as it may be too complicated and quantitative tools are lacking. An in-depth study of this subject would be most informative.


In the News [Top]
  • High-Frequency Trading.
On June 17th, Reuters reported on the consequences of high-frequency trading in commodities. Trading.
  • Eighth Circuit Hears Oral Argument on Debit Card Swipe Fee Limits.
On June 16th, Bloomberg summarized the oral arguments made before the Eighth Circuit Court of Appeals on the constitutionality of the Dodd-Frank Act's debit card swipe fee limits. Oral Argument.
  • Michigan Opens Criminal "Robo-Signing" Investigation.
On June 15th, Bloomberg reported that the Michigan Attorney General has opened a criminal investigation into the propriety of mortgage documentation filed with the Michigan Register of Deeds as part of the foreclosure process. Criminal Investigation.
  • Regulators Divided over Capital Requirements.
On June 15th, Reuters reported that federal regulators are divided on whether the largest U.S. banks should be required to hold more than the 7 percent capital required by Basel III. The Federal Reserve Board and FDIC appear to support an additional 3 percent requirement for the largest banks. The OCC, however, has warned against that requirement. Capital Requirements. On June 16th, Bloomberg reported that members of the Basel Committee are considering a capital surcharge against the largest banks if they grow bigger. Surcharge.
  • Bill Would Raise Shareholder Reporting Threshold.
On June 15th, the Wall Street Journal reported that Representative David Schweikert has introduced a bill raising to 1,000, the number of shareholders a company may have before having to report to the SEC. Legislation. On June 17th, Thomson Reuters published an analysis of the bill, concluding that what is really needed is a more limited exception to who would be considered a shareholder. Analysis.
  • Suing U.S.-Listed Foreign Firms.
On June 15th, Thomson Reuters reported on just one of the hurdles shareholder-plaintiffs face when suing U.S.-listed foreign firms: serving defendants with the complaint. Process Service.
  • Initial Public Offerings.
On June 14th, the New York Times' DealBook discussed the problems associated with the initial public offering process which were made apparent by LinkedIn's IPO and the SEC's recent Reverse Merger Report. IPOs.
  • Regulators Examining Conduit Bonds.
On June 14th, the Los Angeles Times reported that regulators are investigating conduit bonds, which some describe as corporate bonds disguised as municipal bonds. Although conduits comprise 20 percent of all municipal bond offerings, they are responsible for 70 percent of all defaults. Conduits. On June 16th, the Los Angeles Times summarized the conclusions reached by an IRS advisory committee studying conduits. The committee called upon the IRS to issue guidance in the lightly regulated area. Report.
  • Living Wills.
On June 14th, Washington Post columnist Allan Sloan wrote that the living wills required by the Dodd-Frank Act are doomed to fail. Living Wills.
  • FBI Agents Given New Authority.
On June 12th, the New York Times reported that as part of its revision to its Domestic Investigations and Operations guide, the FBI will give its agents greater authority to use surveillance and to search databases and household garbage during a preliminary investigation. Apparent Authority.

Banking Agency Developments [Top]
  • OCC Releases First Quarter Bank Data.
On June 17th, the OCC released its Quarterly Report on Bank Trading and Derivatives Activities. Commercial banks reported trading revenue of $7.4 billion in the first quarter of 2011, 113 percent higher than the fourth quarter of 2010, but 10 percent lower than in the first quarter of 2010. Net current credit exposure, the primary metric the OCC uses to measure credit risk in derivatives activities, declined $23 billion, or 6 percent, to $353 billion. Other credit metrics improved in the first quarter as well. Derivative charge-offs declined 33 percent to $74 million in the first quarter, while past due derivatives fell 22 percent to $42 million. OCC Press Release.
  • Banks Affected by Missouri River Flooding May Close at Their Discretion.
On June 16th, the OCC issued a proclamation allowing national bank offices affected by the flooding along the Missouri River to close at their discretion. OCC Press Release.
  • OCC Issues Bulletin on Proposed Stress Testing Guidance.
On June 15th, the OCC issued a Bulletin on the banking regulators jointly proposed guidance on stress testing for banks with more than $10 billion in total consolidated assets.
  • Banking Agencies Adopt Risk-Based Capital Floor.
On June 14th, the FDIC, Federal Reserve Board and OCC adopted a final rule establishing a floor for the risk-based capital requirements applicable to the largest, internationally active banking organizations as required by the Dodd-Frank Act. A banking organization operating under the agencies' advanced approaches risk-based capital rules is required to meet the higher of the minimum requirements under the general risk-based capital rules and the minimum requirements under the advanced approaches risk-based capital rules. The rule also provides limited flexibility to establish appropriate capital requirements for certain low-risk exposures that, in general, are not held by insured depository institutions, but may be held by depository institution holding companies or nonbank financial companies supervised by the Federal Reserve Board. The final rule will be effective 30 days after publication in the Federal Register, which is expected soon. Joint Press Release.
  • Federal Reserve Board Adopts Interim Rule Regarding Small Bank Holding Company Subordinate Debt.
On June 13th, the Federal Reserve Board adopted an interim final rule that allows small bank holding companies that are S-Corporations or that are organized in mutual form to exclude subordinated debt issued to Treasury under the Small Business Lending Fund from treatment as "debt" for purposes of the debt-to-equity standard under the Board's Small Bank Holding Company Policy Statement. Federal Reserve Board Press Release.
  • Federal Reserve Board Publishes Annual Adjustments to Dollar Threshold for Exempt Consumer Credit and Lease Transactions.
On June 13th, the Federal Reserve Board adjusted Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) by increasing the dollar threshold for exempt consumer credit and lease transactions. Transactions at or below the threshold are subject to the protections of the regulations. These adjustments reflect the annual percentage increase in the consumer price index that was in effect as of June 1, 2011. These adjustments are effective January 1, 2012. The protections of the Truth in Lending Act and the Consumer Leasing Act generally will apply to consumer credit transactions and consumer leases of $51,800 or less in 2012. However, private education loans and loans secured by real property (such as mortgages) are subject to TILA regardless of the amount of the loan. Federal Reserve Press Release (with links to the revised regulations).
  • Federal Reserve Board Publishes Adjusted Fee-Based Trigger for Additional Mortgage Disclosure.
On June 13th, the Federal Reserve Board published its annual adjustment to the amount of fees that triggers additional disclosure requirements under the Truth in Lending Act and the Home Ownership and Equity Protection Act of 1994 for home mortgage loans that bear rates or fees above a certain amount. The dollar amount of the fee-based trigger has been adjusted to $611 for 2012. Federal Reserve Board Press Release.
  • OCC Extends Deadline for Action Plans under Foreclosure Practices Consent Order.
On June 13th, the OCC announced it has extended the timelines for submission of plans, programs, policies, and procedures and foreclosure review engagement letters required by consent orders issued on April 13, 2011 against eight large national bank residential mortgage servicers. At the request of the U.S. Department of Justice and to allow coordination of actions with other agencies at the state and federal level, the OCC extended the deadlines for requirements in Article III through Article IX of the consent orders by 30 days. OCC Press Release.

Treasury Department Developments [Top]
  • FBAR Filing Deadline Extended for Certain Persons.
On June 16th, the Internal Revenue Service and the Financial Crimes Enforcement Network extended to November 1, 2011, the deadline by which persons having signature authority over, but no financial interest in, a foreign financial account in 2009 or earlier calendar years must filed a Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts ("FBAR"). IRS Notice 2011-54.
  • FinCEN Announces Updated Zip Code Validations for BSA Reports.
On June 13th, the Financial Crimes Enforcement Network and the Internal Revenue Service announced they have updated the validation of zip code fields to cover city, state, and zip code. The validation has been enhanced to verify that the city and state are consistent with the first five digits of a U.S. zip code as assigned by the U.S. Postal Service. This is a change from the previous cross-validation of state and the first three digits of the U.S. zip code. The accuracy of the zip code field is particularly important to law enforcement agencies as many query based on their geographic location. This validation is being applied to all BSA E-Filing and paper submissions. FinCEN Notice.

Commodity Futures Trading Commission [Top]
  • Position Limits.
On June 16th, Reuters reported that the CFTC will not adopt speculative position limits anytime soon. Position Limits.
  • CFTC Proposes to Delay Certain Swap-Related Rules.
On June 14th, the CFTC published for comment proposed rules granting temporary exemptive relief from Section 754 of the Dodd-Frank Act regarding certain swap-related requirements that go into effect on July 16, 2011. The relief would be granted in two parts:
  • In part one, the CFTC addresses provisions of Section 754 that would go into effect on July 16, that reference terms such as "swap," "swap dealer," "major swap participant," or "eligible contract participant" that the Dodd-Frank Act requires the CFTC and SEC to "further define." These definitional rulemakings will not be in place by July 16. Accordingly, the CFTC is proposing to temporarily exempt persons or entities from complying with these provisions until the effective date of the definitional rulemaking for such terms or December 31, 2011, whichever is earlier. The exemption would apply only to the extent the provision specifically relates to entities or instruments such as swaps, swap dealers, major swap participants, and eligible contract participants.
  • In part two, the CFTC addresses provisions of the CEA that will apply to certain transactions in exempt or excluded commodities (primarily financial and energy commodities) as a result of the repeal of various Commodity Exchange Act ("CEA") exemptions and exclusions as of July 16, 2011. The Commission is proposing to temporarily exempt such transactions from certain CEA provisions until the repeal or replacement of certain of the Commission's regulations or December 31, 2011, whichever is earlier.
Comments should be submitted on or before July 1, 2011. CFTC Fact Sheet on Proposed Order Addressing Effective Date of Swap Regulations. See also CFTC Open Meeting Webpage (with additional links to documents and Commissioner statements); Bloomberg.

Securities and Exchange Commission [Top]
New Final Rules and Orders
  • SEC Delays Effective Date of Dodd-Frank Act Swap Requirements.
On June 15th, the SEC issued an exemptive order providing guidance as to which of the Title VII requirements of the Dodd-Frank Act will apply to security-based swap transactions as of July 16, 2011, the effective date of Title VII. It also granted temporary relief to market participants from compliance with certain of the Title VII requirements. The guidance makes clear that substantially all of Title VII's requirements applicable to security-based swaps will not go into effect on July 16. It also grants temporary relief from compliance with most of the new Securities Exchange Act requirements that would otherwise apply on July 16. In addition, the order provides temporary relief from Exchange Act Section 29(b), which generally provides that contracts made in violation of any provision of the Exchange Act shall be void as to the rights of any person who is in violation of the provision. Comments should be submitted on or before July 6, 2011. SEC Press Release.
  • Delegation of Authority.
On June 13th, the SEC issued a new final rule delegating authority to the Director of the Division of Enforcement to issue witness immunity orders to compel individuals to give testimony or provide other information. The final rule is effective June 17, 2011, for a period of 18 months, at the end of which the Commission will evaluate whether to extend the delegation. SEC Release No. 34-64649.
Proposed Rules
  • Broker-Dealer Reports.
On June 15th, the SEC published for comment proposed amendments to the broker-dealer financial reporting rule in an effort to strengthen the audits of broker-dealers and the SEC's oversight of the way that broker-dealers handle their customers' securities and cash. The proposed amendments would mandate an audit of the controls that a broker-dealer has put in place and require broker-dealers that maintain custody of customer assets or self-clear transactions to allow SEC staff and the relevant designated examining authority to review work papers of the public accounting firm that audits the broker-dealer and discuss any findings with the accounting firm. The proposed amendments also would require all broker-dealers to quarterly file a proposed new form that would elicit information about the custody practices of the broker-dealer. Comments should be submitted within 60 days after publication in the Federal Register, which is expected during the week of June 20. SEC Press Release. See also Paredes Remarks (requesting comments on particular issues).
Other Developments
  • Edgar's Open Nature.
On June 16th, the Wall Street Journal reported that Johnny Earl Satterwhite has submitted filings with the SEC claiming investments totaling $8 trillion. The filings highlight the open, and unsupervised, nature of the SEC's filing system. Edgar.
  • SEC Inspector General Releases Report on Agency's Cost-Benefit Analyses.
On June 16th, the SEC Inspector General made public his initial report to members of the Senate Banking Committee concerning the economic analyses conducted by the SEC in connection with its Dodd-Frank Act rulemaking. The Inspector General concluded that as a general matter, the SEC conducted proper cost-benefit analyses with respect to the six rulemakings at issue. However, better coordination and communication is needed between the agency's cost-benefit teams. SEC Inspector General's Report.
  • SEC Concludes That Certain Stanford Victims Are Entitled to SIPA Relief.
On June 15th, the SEC announced that it has concluded that certain individuals who invested money through the Stanford Group Company, a U.S. broker-dealer owned and used by R. Allen Stanford to perpetrate a Ponzi scheme, are entitled to the protections of the Securities Investor Protection Act of 1970 ("SIPA"). The Commission has therefore asked the Securities Investor Protection Corporation to initiate a court proceeding under SIPA to liquidate the broker-dealer. SEC Press Release. On June 14th, the Washington Post reported that Senator David Vitter said he would block the confirmation of two nominees to the SEC, Luis Aguilar and Daniel Gallagher, until the SEC said when it would decide whether Stanford's victims would be compensated. Nominees.
  • Stop Order Proceedings Instituted Against Two Chinese Firms.
On June 13th, the SEC announced that it has instituted proceedings to determine whether stop orders should be issued suspending the effectiveness of registration statements filed by two companies - China Intelligent Lighting and Electronics Inc. and China Century Dragon Media Inc. The SEC instituted the stop order proceedings against each company after the companies' independent auditor resigned and withdrew its audit opinions on the financial statements included in the companies' registration statements. SEC Press Release (with links to orders).

Exchanges and Self-Regulatory Organizations [Top]
Chicago Board Options Exchange
  • SEC Approves Qualified Contingent Cross Order.
On June 13th, the SEC approved the Chicago Board Options Exchange's proposal to establish a qualified contingent cross order. SEC Release No. 34-64653.
  • CBOE Proposes the Trading of Single Stock Dividend Options.
On June 13th, the SEC provided notice of the Chicago Board Options Exchange's proposal to amend certain rules to provide for the listing and trading of options that overlie the ordinary cash dividends paid by an issuer over an annual, semi-annual, or quarterly "accrual period." The options will be cash-settled, have European-style exercise and be P.M.-settled. Comments should be submitted on or before July 8, 2011. SEC Release No. 34-64654.
Financial Industry Regulatory Authority
  • FINRA Announces Implementation Date for Anti-Spinning Rules.
On June 17th, FINRA announced in a Regulatory Notice that September 26, 2011, is the new implementation date for provisions of FINRA Rule 5131 addressing spinning and market orders in the allocation of new issues. The notice also answers several interpretive questions regarding the new rule. FINRA Regulatory Notice 11-29.
  • FINRA Proposes Amendment Establishing GASB Accounting Support Fee.
On June 16th, FINRA requested comment on an amendment to its By-Laws establishing the SEC-ordered annual accounting support fee for the Governmental Accounting Standards Board. The fee would be allocated among FINRA member firms based on the municipal securities transactions reported to the Municipal Securities Rulemaking Board and collected quarterly. Comments should be submitted on or before August 1, 2011. FINRA Regulatory Notice 11-28.
  • SEC Extends TRACE Pilot.
On June 14th, the SEC granted immediate effectiveness to FINRA's extension to January 27, 2012, the pilot program in FINRA Rule 6730(e)(4) that exempts from reporting to FINRA's Trade Reporting and Compliance Engine ("TRACE"), transactions in TRACE-Eligible Securities that are executed on a facility of the NYSE in accordance with NYSE Rules 1400, 1401, and 86, and reported to NYSE in accordance with NYSE's applicable trade reporting rules and disseminated publicly by NYSE. Comments should be submitted within 21 days after publication in the Federal Register, which is expected during the week of June 20. SEC Release No. 34-64665.
International Swaps and Derivatives Association
  • Documentation for Cleared Swaps.
On June 16th, the Futures Industry Association and the International Swaps and Derivatives Association published the FIA-ISDA Cleared Derivatives Execution Agreement as a template that can be used by participants in the cleared swaps markets in negotiating execution-related agreements with counterparties to over-the-counter derivatives that are intended to be cleared. ISDA Press Release.
National Futures Association
  • Information Notice on CFTC Commodity ETF Amendments.
On June 17th, the National Futures Association advised members of the CFTC's amendments that provide relief from certain disclosure, reporting, and recordkeeping requirements for commodity pool operators of commodity pools whose units of participation are listed and traded on a national securities exchange. NFA Information Notice I-11-10.

Judicial Opinions [Top]
  • Pattern of Disclosure does not Create Duty of Disclosure.
On June 17th, the Eighth Circuit held that a pattern of disclosure does not create a duty to disclose. Securities fraud plaintiffs alleged that an issuer's past pattern of disclosing problems at its facilities required it to disclose the problems that occurred during the proposed class period. The Court rejected that contention noting that the plaintiffs cited no case law in support of their argument. The Court further noted that plaintiffs failed to adequately allege scienter. Patel v. MEMC Electronic Materials, Inc.
  • Federal District Courts May Seize the Passports of Judgment-Debtors.
On June 16th, the Seventh Circuit held that a federal district court has the authority to temporarily seize the passports of judgment-debtors who are subject to a production of assets order. The facts presented the rare case where such an order was justified in that debtors had previously transferred abroad all of the funds subject to the order and were simultaneously hesitant to disclose information that would have revealed those transfers. Bank of America, N.A. v. Veluchamy.
  • Law Firm Had No Independent Claim to Work Product Protections.
On June 14th, the Federal District Court for Kansas addressed an issue of first impression in that District, whether a law firm may independently claim work product protection when the client has waived it. It holds that the law firm cannot and, moreover, that the firm's "entire file", not just the "end product", must be produced. That outcome was particularly applicable where, as here, the defendant's interests and those of the firms were not aligned. The defendant explicitly asserted reliance on counsel's advice in opposing the penalties sought by the SEC. Additionally, the Court adopted the magistrate's finding that the law firm had waived any independent right to assert work product protection it may have had respecting disclosure of documents created for law office use and review. SEC v. McNaul.
  • Supreme Court Rules in Favor of Janus Capital Group.
On June 13th, the Supreme Court honored the corporate form and held that an investment adviser cannot be held liable for allegedly false statements made in a mutual fund prospectus that it did not file. Shareholders of the investment adviser's parent company brought a Rule 10b-5 lawsuit against the parent and adviser alleging that the prospectuses for the mutual funds for which the adviser provided advisory services contained false and misleading statements and seeking to hold the adviser liable for them. In a 5-4 decision, the Supreme Court held that the adviser cannot be held liable for the statements made in the fund prospectuses. The fund, not the adviser, filed the prospectuses with the SEC and the Court strictly respected the corporate form, noting that only one of the fund's trustees was also associated with the adviser. Janus Capital Group, Inc. v. First Derivative Traders. See also Reuters (reaction to Court's decision and predicted consequences).
  • Court Refuses to Retroactively Apply Dodd-Frank Act Provision.
On June 6th, the Northern District Court for California refused to retroactively apply Section 929M(2)(b) of the Dodd-Frank Act, which authorizes the SEC to sue for aiding and abetting a primary violation of the Investment Advisers Act. The SEC alleged defendants made misleading statements concerning the Charles Schwab YieldPlus Fund. Partially granting defendants' motion to dismiss, the Court held that nothing in the Dodd-Frank Act suggests that it was meant to apply retroactively. Since the events at issue occurred prior to the Act's enactment, the Court dismissed the charges based on Section 929M(2)(b). SEC v. Daifotis.

Rules Effective Dates [Top]
  • Beneficial Ownership Reporting Requirements and Security-Based Swaps - Effective July 16, 2011.
The SEC readopted, without change, certain portions of Rules 13d-3 and 16a-1, thus preserving the application of existing beneficial ownership rules to persons who purchase or sell security-based swaps after the effective date of new Section 13(o) of the Securities Exchange Act of 1934. Section 13(o) provides that a person shall be deemed a beneficial owner of an equity security based on the purchase or sale of a security-based swap only to the extent that the SEC adopts rules after making certain determinations with respect to the purchase or sale of security-based swaps. After making the necessary determinations, the SEC readopted the relevant portions of Rules 13d-3 and 16a-1 to confirm that, following the July 16, 2011, statutory effective date of Section 13(o), persons who purchase or sell security-based swaps will remain within the scope of these rules to the same extent as they are now. 76 FR 34579.

Winston & Strawn Speaking Engagements and Publications [Top]
  • SEC Adopts Final Rules to Establish Whistleblower Program.
On May 25, 2011, the Securities and Exchange Commission (the "SEC" or the "Commission") adopted final rules (the "Final Rules") to implement Section 21F of the Securities Exchange Act of 1934, as amended (the "Exchange Act") - "Securities Whistleblower Incentives and Protection." Briefing.

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