Saturday, December 31, 2011

SEC Issues Revised Dodd-Frank Implementation Schedule at Year End

On December 30, 2011, the SEC revised its Dodd-Frank implementation timetable, moving a number of items planned for December 2011 into 2012 time frames. All of the regulatory activity around the Title VII derivatives regulatory regime is now planned for the July-December 2012 time frame. Similarly, the adoption of regulations setting up a registration regime for municipal securities advisors has been moved to July-December 2012.

Regulations regarding disclosure related to conflict minerals under Section 1502 of Dodd-Frank and disclosure by resource extraction issuers under Section 1504 are slated to be adopted in the January-June 2012 time period. The SEC also plans to virtually complete Title IV implementation in the first half of 2012, adopting regulations adjusting the threshold for qualified client as directed by Section 418 and reporting to Congress on the study of the costs and benefits of real time reporting on short sale positions as directed by Section 417. However, a report to Congress on a study on the state of short selling on exchanges and in the over-the-counter markets under Section 417 will wait until the second half of 2012.

The adoption of regulations implementing the Volcker Rule prohibitions on proprietary trading and certain relationships with hedge funds and private equity funds is scheduled for the July-December 2012 time frame.

The adoption of risk retention rules for securitizers of asset-backed securities is set for the first half of 2012. The SEC is also slated to complete the implementation of Title VIII in the first half of 2012 by adopting rules regarding standards for clearing agencies designated as systemically important under Section 805 and adopting rules regarding the process to be used by designated clearing agencies to provide notice of proposed changes under Section 806.

1 comment:

mikestarks said...

Mr hamilton:
Do you advise on Reg D procedures and private offerings?

thanks

Mike