SEC Proposes Reducing Settlement by One Day to T+2

The Securities and Exchange Commission (the “SEC”) has proposed to amend its Rule 15c6-1(a) to require broker-dealers to settle most non-exempt securities in T+2 instead of T+3, although shorter settlement is possible.  See proposal, here. Comments are due by December 5, 2016.  There seems to be little opposition to the basic shortening, which comes some... Read more »

FINRA to Require TRACE Reports on Treasury Transactions

The Securities and Exchange Commission (the “SEC”) has approved the Financial Industry Regulatory Authority’s (“FINRA”) plan to require, as of July 10, 2017, the reporting by FINRA member firms of transactions in U.S. Treasuries to the Trade Reporting and Compliance Engine (“TRACE”).  See FINRA Regulatory Notice 16-39, October 2016, here.  The rules will apply to... Read more »

NY Department of Financial Services Proposes New Cybersecurity Rules

In September of 2016, the NY Department of Financial Services (the “DFS”) proposed rules to require anyone operating under the NY banking law, insurance law or financial services law (a “Covered Entity”) to adopt a cybersecurity program and a cybersecurity policy, to appoint a chief information officer (a “CIO”), to do penetration and vulnerability testing,... Read more »

Court Dismisses Citizen Suit Against Oneida for Solar Farm Agreement

Given the state and federal incentives for solar energy, and the lowered cost of solar panels, companies are seeking to lease land in rural New York to build solar farms.  The Oneida Daily Dispatch reported in April 2016 that a Madison County Judge had dismissed an Article 78 lawsuit against the city of Oneida.  See here.  The suit... Read more »


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