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Disclosure and Beyond: Restructuring the U.S. Equity Markets

BRIEFING GUIDE to the SEC’s Aggressive Agenda to Head off the Next “Big Squeeze” On Friday, February 25, 2022, the Securities and Exchange Commission (SEC) proposed its latest round of GameStop rule proposals. In addition to enhanced public disclosures of short sales by institutional investors, the Commission announced a 30-day extension of the comment period […]

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T+1: The Future is Now (or at least as early as 2024)

The SEC Boldly Sets Course for T+1 and T+0 While real-time settlement is still something that may happen far in the future, perhaps on the Starship Enterprise, T+1 is now imminent. On February 9, 2022, the Securities and Exchange Commission proposed to make T+1 a reality. The proposal aimed at reducing risks in clearance and […]

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How Would Cross-Border Payments Change in a Digital Currency World?

World Bank, BIS and SWIFT weigh in on CBDCs Widespread adoption of central bank digital currencies (CBDC) could revolutionize cross-border payments by reducing friction and making it possible for T+1 or even T+0 settlement of cross-border trades. The Fed’s Digital Currency discussion paper is the central bank’s first step in a public discussion with stakeholders […]

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The Fed Weighs in on a ‘Digital Dollar’

Vast Cross-border Implications for Central Bank Digital Currencies A discussion paper published on January 20th invites the public to explore with the U.S. Federal Reserve Board the creation of a digital version of the U.S. dollar. A Central Bank Digital Currency (CBDC) backed by the Federal Reserve would be designed, according to the Fed’s paper, […]

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Lenders and Borrowers Sound off on the SEC’s Disclosure Proposal

Giving the SEC an Earful and Sounding the Alarm The Securities and Exchange Commission’s (SEC) securities lending disclosure proposal has drawn sharp rebuke from both securities lenders and borrowers. Lending principals criticized the proposal on everything from cost, lack of clarity, and overbroad scope to the rule’s general inequity. They also warned of a host […]

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FIRST DO NO HARM

A Hippocratic Oath for Securities Lenders [1] If the Securities and Exchange Commission approves the many industry requests for delay of its proposed 10c-1 reporting rule for securities loans, leaders in the Global Association of Securities Lending Associations (GASLA) should move quickly to create a more efficient and lower cost disclosure regime. Congress will not […]

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Digitized Finance Testing Approved by European Union

The European Commission has reached agreement with legislators and financial trade groups on a digitized infrastructure to reshape the EU and, by extension, the global securities markets. The resolution affects all transactions involving EU securities, including securities loans, by (1) green-lighting the Distributed Ledger Pilot Regime, an effort to foster fintech innovation in the EU, and (2) delaying mandatory buy-ins, a highly contentious aspect of the ongoing sweeping reforms to the EU’s securities settlement system.

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Beneficial Owners: “Most at risk, yet least served” by Disclosures

Comments to SEC on Proposed 10c-1 Reporting by Securities Lenders Excerpts from CSFME comment letter on proposed SEC Rule 10c-1, submitted 15 December 2021 “The Honorable Gary Gensler, Chairman, U.S. Securities and Exchange Commission: “With regard to the above-cited 10c-1 disclosure system, my colleagues and I consider inclusion in the rule proposal of an optional […]

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“Wisely and Slow; They Stumble that Run Fast.”

Finding a Better Value Proposition for the SEC’s Sec Lending Disclosure Rule The SEC has proposed a radical and potentially very costly reporting regime for securities finance transactions to increase transparency “to brokers, dealers, and investors.” Notably, the rule release’s[1] extensive economic analysis section includes some potential alternatives to the proposed new reporting structure. While […]

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