RECENT CLIENT MATTERS
The following are some of our recent client matters:
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Comment letters to FDIC and Federal Reserve Board concerning Regulation Q repeal
Analysis of Regulation D definition of "deposit" in connection with sweep arrangement
Paper on implications of financial crisis for modern portfolio theory and Uniform Prudent Investor Act
Letter to FASB concerning treatment of money market funds as cash equivalents for financial statement reporting purposes
Comment letter on SEC proposal regarding regulation of municipal advisors
Analysis of SEC study on treatment of securities brokers as fiduciaries
Conceptualizing proposal for regulatory treatment of principal trades by broker-dealers
Analysis of regulatory criteria for designation of nonbank financial companies as "systemically important"
Analysis of Volcker Rule
Analysis of proposals by Financial Stability Oversight Council
Analysis of issues relating to "shadow banking system"
Comment letter on Moody's proposal to revise rating criteria for money market funds
Analysis of President's Working Group recommendations on money market funds
Comment letter on FDIC proposal to extend guarantee of noninterest bearing transaction accounts
Analysis comparing broker-dealer suitability standard with trustee fiduciary standard
Analysis of SEC proposal to revise Rule 12b-1 mutual fund fees
Paper on implications of Dodd-Frank Act for bank holding companies
Analysis of various titles of Dodd-Frank Wall Street Reform and Consumer Protection Act
Paper analyzing the reasonableness standard for service provider fees under the Employee Retirement Income Security Act (ERISA)
Drafting legislative amendments to financial services reform legislation
Analysis of new Basel international liquidity framework for banks
Analysis of financial reform legislation
Analysis of implications of new consolidated accounting rules (FAS 167) for bank capital
Advice regarding FINRA rules on "parking" of brokerage license and applicability of certain FINRA rules to bank employees engaged in securities transactions
Analysis of proposed Investor Protection Act of 2009 and related proposals
Analysis of legislation proposed by Obama Administration to reform the financial regulatory system
Advice for securities brokers on implications of fiduciary status under Investment Advisers Act of 1940
Analysis of Administration proposal to impose a fiduciary duty on securities broker-dealers
Analysis of Financial Accounting Standards Board issuance on consolidated accounting (FAS 167) and implications for money market mutual funds
Memorandum analyzing Treasury proposal to establish a regulatory mechanism for resolving failing financial companies
Memorandum on meaning of "systemic risk" and proposals to address systemically significant financial institutions
Memorandum on why Federal Reserve Board lacked authority for systemic oversight under "umbrella" regulation provisions of Gramm-Leach-Bliley Act
| White paper on "The Truth About Money Funds"
Critical analysis of Group of Thirty Report on Financial Regulation
Critical analysis of new Moody's and Fitch criteria for rating money market funds
Memorandum on Congressional financial reform activities
Memorandum on fiduciary Investments in money market funds in a zero or negative interest rate environment
Memorandum on eligibility of certain financing arrangements for FDIC temporary liquidity guarantee program
Expert witness report in litigation on bank commodity trading activities
Advice to financial industry trade association on regulatory reform proposals and issues
Memorandum on Emergency Economic Stabilization Act of 2008
White paper examining causes and consequences of current financial crisis, the government’s response, and financial restructuring initiatives
Memorandum on risk characteristics of certain money market mutual funds
White paper examining Federal Reserve Board authority to extend liquidity to broker-dealers and implications of Bear Stearns crisis for federal safety net and future financial regulation
Memorandum on scope of coverage of various customer account arrangements under Treasury Department’s Temporary Guarantee Program for money market mutual funds
Expert witness testimony in Financial Industry Regulatory Authority (FINRA) arbitration proceeding.
Memorandum on applicability of various exemptions for banks from broker-dealer regulation under Regulation R
Memorandum on exemption from Section 23A of the Federal Reserve Act for bank purchases of assets from affiliated money market mutual funds
Advice concerning investment of trust assets in bank deposits
Memorandum on FDIC pass-through insurance coverage for specific deposit account arrangements
Advice on risk weightings of specific assets under Basel II capital standards
Advice on scope of FDIC insurance coverage for sweep accounts in event of bank failure under new FDIC regulation
Advice on rule proposal by Financial Industry Regulatory Authority to exempt bank dual employees from certain broker-dealer supervision requirements
Memorandum on covered bonds as partial substitute for Fannie Mae and Freddie Mac debt
Memorandum on risk characteristics of GSE debt in light of Housing and Economic Recovery Act of 2008
Advice on mutual fund filing fees under particular state laws
Advice on state law requirements pertaining to solicitation of fiduciary business under reciprocal statutes of another state
Memorandum on conflicts of interest regulation applicable to broker-dealers and investment advisers
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