NAIC: Financial Analysis Solvency Tools Working Group (E) – Complex Ownership Structures (SIFMA AMG)
SIFMA AMG provided comments to the National Association of Insurance Commissioners (NAIC) on the Financial Analysis Handbook Exposure Draft.
Court:
U.S. Court of Appeals
(Eleventh Circuit)
Amicus Issue:
Whether the two-thirds one-third allocation between industry members and the participant exchanges is contrary to the Exchange Act and arbitrary and capricious. Whether the retrospective allocation of costs is contrary to the Exchange Act and arbitrary and capricious. Whether the SEC failed to conduct an adequate independent analysis of the CAT funding rules. Whether the uncertain, escalating and uncontrolled costs of the CAT system render the order arbitrary and capricious.
Counsel of Record:
Paul, Weiss, Rifkind, Wharton & Garrison LLP
Lorin L. Reisner
Kannon K. Shanmugam
Brian M. Lipshutz
Yishai Schwartz
David A. Hopen
Other Amici:
Committee on Capital Markets Regulation
Alternative Investment Management Assoc.
Virtu Financial, Inc.
Investment Company Institute
Managed Funds Assoc.
SIFMA AMG provided comments to the National Association of Insurance Commissioners (NAIC) on the Financial Analysis Handbook Exposure Draft.
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) and reiterated comments made in their…
SIFMA, The American Bankers Association (ABA), the American Fintech Council (AFC), the Bank Policy Institute (BPI), the Electronic Transactions Association…