On November 21, 2025, the Structured Finance Association, on behalf of the risk transfer market, received no-action relief on the issue of registration as a commodity pool operator (“CPO”) from the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”). This long-awaited relief provides greater certainty that participants in certain
Matthew Bisanz
SEC Signals Incoming Relief For De Minimis Security-Based Swap Dealers
By Anna T. Pinedo, Matthew Bisanz & Kelly Truesdale on
On October 29, 2025, Paul Atkins, Chairman of the Securities and Exchange Commission (“SEC”), signaled that he will ask SEC staff to evaluate relief for certain firms who engage in a de minimis level of security-based swap (“SBS”) dealing. While the relief will not be issued as long as the government shutdown persists, his statement…
Stablecoin & Digital Assets and Tokenization Resource Centers
By Matthew Bisanz on
Posted in Digital Assets
Stablecoins and tokenization are revolutionizing markets, finance, and money flows. From ongoing implementation of the GENIUS Act to the daily tokenization of new asset classes, continuous innovation is the only constant.
Our Stablecoin & Tokenization Resource Centers closely track the latest commercial, regulatory, and legislative issues that are shaping these trends. More importantly, they help…
NFA Streamlines Process for Virtual Currency Activities by CFTC Registrants
By Matthew Bisanz & Kelly Truesdale on
Posted in CFTC, Digital Assets
On October 17, 2025, the National Futures Association (“NFA”) announced a proposal to repeal requirements that firms that are registered with the Commodity Futures Trading Commission (“CFTC”) must make certain disclosures to customers regarding virtual currency activities.
The repeal of the disclosure requirements will take effect 10 days after the CFTC receives NFA’s proposal, unless…
SEC Grants No-Action Relief to Registered Investment Advisers and Certain Registered Investment Companies to Treat a State Trust Company Providing Crypto Asset Custody Services as a “Bank”
On September 30, 2025, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission granted no-action relief that allows, subject to numerous conditions: (i) investment advisers registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”); and (ii) investment companies registered under the Investment Company Act of…
Digital (Tokenized) Bonds: What to Know About a Growing Asset Class
By Matthew Bisanz & Steffen Hemmerich on
Webinar | August 11, 2025
1:00 p.m. – 2:00 p.m. EDT
Register here.
Tokenized bonds are one asset class that is quickly emerging from the amorphous pool of digital asset projects. Hosted by PLI, this webinar will provide an overview of the fundamentals of tokenized bonds, how they are structured, and how they have…
More Than Maple Syrup: Foreign Bank Opportunities in Canada
By Matthew Bisanz on
Posted in Events, Financial Services
Webinar | July 28, 2025
12:00 p.m. – 1:00 p.m. EDT
Register here.
In this webinar, the Mayer Brown team will be joined by Torys LLP to discuss the ways in which US and other foreign banks can engage in business in Canada.
Canada has a vibrant economy and abundant natural resources that present…
FAQs – What US clients need to know about PISCES – a new secondary private stock market in the UK
By Musonda Kapotwe, Peter Pears & Matthew Bisanz on
- A key challenge for private companies is that, at early stages in their growth, there are no standardised ways for shareholders to realise their gains (e.g., where their shares have increased in value) or to
US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform
Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”). This proposal is intended to reduce the likelihood of the eSLR requirement being the binding capital constraint for US GSIBs and, thereby, enhance the ability of US GSIBs…
Out With a Whimper: BCBS Publishes Climate Disclosure Framework
By Matthew Bisanz & Musonda Kapotwe on
On June 13, the Basel Committee on Banking Supervision (“BCBS”) published its framework for the disclosure of climate-related financial risks. The framework is entirely voluntary and has several notable changes from the 2023 proposal. In this brief Legal Update, we highlight those changes and discuss why the climate disclosure framework will have at best a…