Zachary J. Zweihorn

On January 30, 2020, the CFTC proposed a rule that largely codifies no-action relief the Commission previously issued related to the treatment of: (1) package transactions; (2) error trad...

On December 18, 2019, the CFTC proposed rules that would modify and codify the cross-border application of certain of its Title VII swap rules to both U.S. and non-U.S. registered swap de...

Broker-dealer custody of on-blockchain assets has been a key hurdle in the development of a more regulated financial infrastructure for digital assets in the United States. In a joint sta...

On June 21, 2019, the SEC adopted security-based swap (SBS) capital, margin and segregation requirements (the SEC Rules) for SBS dealers (SBSDs) and major SBS participants, revised the ca...

House Financial Services Committee Chair Maxine Waters (D-CA) has released a discussion draft of legislation to amend the SEC’s approach to considering and granting waivers to automatic...

The SEC adopted its long-awaited Regulation Best Interest, establishing new standard of conduct regulations for SEC-registered broker-dealers and their associated persons that are natural...

Davis Polk partner Annette Nazareth was the contributing editor for the second edition of Getting the Deal Through: Financial Services Compliance, a compilation of the rules and approache...

  Davis Polk partner Annette Nazareth and counsel Zachary Zweihorn co-authored the “Federal Securities Regulation: Securities Act and Exchange Act” section of the American Bar Associa...

Blockchain technology continues to be a lively topic of conversation in legal, business and technology circles. This memo focuses on several key topics for companies considering whether a...

Last week, the SEC staff published new detailed guidance on its views of when a digital asset may be considered a security, in the form of two documents:  a guidance “framework” issue...