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Jason Grimes is an associate in the firm’s financial institutions and futures and derivatives practice groups. He advises clients on a wide range of regulatory matters, including compliance with various state and federal banking laws, and compliance with the Commodity Exchange Act.
- Advised a CFTC-registered swap dealer on compliance issues related to trading on swap execution facilities
- Advised a major financial institution in connection with the treatment of non-deliverable forward transactions under the Dodd-Frank Act.
- Advised financial institutions with respect to compliance with capital adequacy requirements.
- Representation of Synchrony Financial (GE Capital’s North American retail finance business) in connection with its approximately $2.95 billion initial public offering.
- Advised private fund regarding laws related to non-bank commercial lending.
Pro Bono
- Advised client regarding organization of an educational non-profit corporation.
January 26, 2018, Cov Financial Services
On January 24, 2018, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) published a Request for Information (“RFI”) on its civil investigative demand (“CID”) process. This is the first in a series of planned RFIs on the Bureau’s activities. In the RFI, the CFPB recognizes that “responding to a CID can impose burdens on...… Continue Reading
November 3, 2017, Cov Financial Services
On November 2, 2017, Consumer Financial Protection Bureau (“CFPB” or “Bureau”) Director Richard Cordray delivered remarks at a meeting of the Consumer Advisory Board in Tampa, Florida. Director Cordray’s remarks touched on the following issues: Reverse Mortgages: Noting that Florida is home to millions of senior Americans, Director Cordray discussed reverse ...
November 1, 2017, Cov Financial Services
On October 26, 2017, the Commodity Futures Trading Commission (“CFTC”) issued an order postponing the automatic lowering of the swap dealer de minimis threshold. Instead of dropping from $8 billion in notional value (measured over the prior 12-month period) to $3 billion on December 31, 2018, which would have required firms to begin tracking swap...… Continue ...
August 29, 2017, Cov Financial Services
The U.S. Commodity Futures Trading Commission (the “CFTC” or the “Commission”) has been very active since the beginning of this year, despite the change in Presidential Administration, the lack (until recently) of appointed Commissioners, and the turnover of leadership at both the Commission and Division level. Notably, the Commission has announced over 20 ...
August 28, 2017, Covington Alert
The U.S. Commodity Futures Trading Commission (the “CFTC” or the “Commission”) has been very active since the beginning of this year, despite the change in Presidential Administration, the lack (until recently) of appointed Commissioners, and the turnover of leadership at both the Commission and Division level. Notably, the Commission has announced over 20 ...
August 18, 2017, Cov Financial Services
For nearly six months following former Chairman Timothy G. Massad’s resignation from the Commodity Futures Trading Commission (“CFTC”), the CFTC operated with only two commissioners, current Chairman J. Christopher Giancarlo and Commissioner Sharon Y. Bowen. Even with only two commissioners, the CFTC was able to undertake several regulatory initiatives, ...
July 7, 2017, Cov Financial Services
On July 6, 2017, the Commodity Futures Trading Commission (“CFTC”) announced that it had granted LedgerX registration as a swap execution facility (“SEF”). LedgerX is a platform that will trade and clear options on bitcoin. LedgerX has also applied to become a derivatives clearing organization. If approved, LedgerX “would be the first federally regulated ...
June 12, 2017, Cov Financial Services
On June 8, 2017, Acting Chair J. Christopher Giancarlo of the Commodity Futures Trading Commission (“CFTC”) made his request for the CFTC’s budget for fiscal year 2018 (“FY 2018”) to the House Appropriations Committee Subcommittee on Agriculture, Rural Development and Related Agencies (“Subcommittee”). Acting Chair Giancarlo is seeking an increase in the CFTC’s ...
May 26, 2017, Cov Financial Services
On May 22, 2017, the Commodity Futures Trading Commission (“CFTC”) announced the finalization of amendments to its whistleblower rules. The most important change is the CFTC’s assertion of the authority to enforce Section 23(h)(1) of the Commodity Exchange Act (“CEA”), which prohibits retaliation against whistleblowers. When it originally promulgated its ...
May 24, 2017, Cov Financial Services
On May 17, 2017, the Commodity Futures Trading Commission (“CFTC”) announced the launch of its financial technology (“FinTech”) initiative, LabCFTC. Per the agency, the initiative is designed to “promot[e] responsible FinTech innovation to improve the quality, resiliency, and competitiveness of the markets the CFTC oversees.” According to Acting Chair J. ...
May 24, 2017, Cov Financial Services
On May 24, 2017, the U.S. Court of Appeals for the D.C. Circuit held en banc oral argument in the rehearing of PHH Corp., et al. v. Consumer Financial Protection Bureau (“PHH”). The lively oral argument extended well beyond the time originally allotted by the Court, as lawyers for PHH, the Department of Justice, and...… Continue Reading
April 24, 2017, Covington Alert
On April 19, 2017, the House Financial Services Committee (the “Committee”) released a new “discussion draft” of the Financial CHOICE Act, its comprehensive regulatory reform bill (“CHOICE Act 2.0”). The Committee released the first version of the bill (“CHOICE Act 1.0”) in June 2016.
February 3, 2017, Covington Alert
Throughout his campaign, President Donald Trump promised to curtail financial regulations, particularly those promulgated under the Dodd-Frank Act. President Trump argued frequently that the regulations issued under the act have proven overly burdensome and, among other things, limited job growth. This afternoon, the President took his first formal step in ...
January 19, 2017, Covington Alert
One of the most sweeping changes brought about by the Dodd-Frank Act was the introduction of a new regulatory framework for swaps trading. In 2013, the Commodity Futures Trading Commission (“CFTC”) finalized its rules on swap execution facilities (“SEFs”) and swaps trading on SEFs. Less than four years after these rules were finalized, the change in Presidential ...
November 30, 2016, Covington Alert
The Commodity Futures Trading Commission is set to begin its trial of Donald R. Wilson and his proprietary trading firm, DRW Investments, LLC (“DRW”) on December 1, 2016. In advance of this trial, this alert provides the legal theory that will be tested during this trial and other observations related to the CFTC’s pursuit of attempted manipulation.
November 14, 2016, Covington Alert
On November 8, 2016, American voters elected Republican Donald J. Trump as President. In addition, Republicans maintained control of the House of Representatives and the Senate. As the campaign rhetoric fades into the background over the coming weeks and months, the business of transitioning to a new administration will begin in earnest. The results of the ...
October 20, 2016, Covington Alert
On October 19, 2016, the Board of Governors of the Federal Reserve System (Federal Reserve), Office of the Comptroller of the Currency (OCC), and Federal Deposit Insurance Corporation (FDIC) (collectively the “Agencies”) released a joint Advance Notice of Proposed Rulemaking (ANPR) requesting public comment on enhanced cybersecurity standards that would apply to ...
October 12, 2016, Covington Alert
Insider trading is a familiar term to participants in the equities markets; however, this term now has application in the swaps, futures, and commodities markets regulated by the U.S. Commodity Futures Trading Commission (CFTC). In a time of aggressive enforcement, financial market participants should be aware that insider trading is a high priority for the CFTC ...
August 30, 2016, Covington Alert
As election season enters full swing, with political candidates at all levels actively soliciting campaign donations from individuals and companies, it is an ideal time for all companies to review the policies and procedures in place for political donations. While the SEC’s pay-to-play rules governing registered investment advisers and their “covered associates” ...