FCA Letter on Post-Brexit Booking Arrangements

The U.K. Financial Conduct Authority (the “FCA”) has issued a “Dear CEO” letter on August 8, 2018, in which it makes clear that post-Brexit, the FCA is open to many different booking arrangements to be utilized by regulated U.K. investment firms for booking trades done with or on non-U.K. European firms. We are open to a... Read more »

CFIUS Update Passed by Congress

On August 1, 2018, the U.S. Senate passed the Foreign Investment Risk Review Modernization Act (“FIRRMA”) as part of the Defense Authorization Bill (Title XVII).  FIRRMA changes and updates the law setting up the Committee on Foreign Investment in the United States (“CFIUS”), which allowed CFIUS to review certain acquisitions by and mergers with foreign... Read more »

California Adopts New Data Privacy Law

In late June, the California legislature adopted, and Governor Jerry Brown later signed into law, the California Consumer Privacy Act of 2018.  See website.  The new law was adopted shortly after the effectiveness of the EU’s General Data Protection Regulation (the “GDPR”), and in the wake of public outcry over data protection violations.  While it... Read more »

SEC Increases Thresholds for “Smaller Reporting Company”

On June 28, the Securities and Exchange Commission increased the thresholds for “smaller reporting companies” (“SRCs”) and made certain other amendments designed to enlarge the category.  See here. “SRCs” are the lowest category of reporting companies (large accelerated filers, accelerated filers, non-accelerated filers and SRCs).  They need file only two years of audited financial statements,... Read more »


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