On July 8, 2026, the staff (the “Staff”) of the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC”) issued a no-action letter (the “No-Action Letter”) in response to an incoming letter submitted on behalf of UBS Group AG (the “Incoming Letter”), addressing the application of the U.S. Securities Act
Matthew Bisanz
US Regulators Finalize Data Standards to Implement the Financial Data Transparency Act
Several federal financial regulators (the “Agencies”) have approved an interagency final rule to establish data standards that promote interoperability of financial regulatory data (the “Final Rule”). The Final Rule finalizes an interagency proposal that was issued in 2024. The Agencies received over 150 unique comments on the proposal from a wide range of stakeholders, including…
The Odds Are In: CFTC Proposes Framework for Event Contracts and Prediction Markets
On June 10, 2026, the Commodity Futures Trading Commission (the “CFTC” or the “Commission”) published a notice of proposed rulemaking (the “Proposal”) suggesting comprehensive amendments to CFTC Regulation 40.11 and adding a new Appendix F to Part 40 concerning event contracts traded on prediction markets. The Proposal would further specify the types of event contracts…
CFTC Issues Request for Comment and Staff Advisory on Prediction Markets
On March 12, 2026, the Commodity Futures Trading Commission (“CFTC”) released two documents regarding “event contract” derivatives traded on prediction markets. The CFTC issued an Advance Notice of Proposed Rulemaking (“ANPRM”) requesting public comment on the regulation of prediction markets. The CFTC’s Division of Market Oversight issued a staff advisory providing guidance to designated contract…
Fintech Xchange 2026
Conference | February 4-6, 2026
Mayer Brown is pleased to partner with the Fintech Center at the University of Utah for the Fintech Xchange conference on February 4-6, 2026. Our Partner Matt will speak on the panel “Systemic impact of the GENIUS Act.”
Launched in 2023, the Fintech Center at the University of Utah unites…
CFTC Staff Partially Reinstate CPO Exemption for RIAs
On December 19, the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”) issued no-action relief from commodity pool operator registration for SEC-registered investment advisers to certain private funds. This relief effectively reinstates the registration exemption previously provided by Rule 4.13(a)(4) for managers to private funds offered solely to qualified…
Risk Transfer Market Receives CPO Registration Relief from CFTC
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…
SEC Signals Incoming Relief For De Minimis Security-Based Swap Dealers
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
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
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…

