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The Plot Thickens
July 14, 2022

Like a Netflix thriller or a Robert Ludlum spy novel, we did our best last week to leave our readers in suspense on digital asset jurisdiction and enforcement. While jurisdiction was the big theme last week, the plot thickens this week as authors Peter Malyshev and Michael Ena take a deep dive into enforcement − what's happened to date and what they expect to see in the weeks and months to come. Additionally, as if on cue, a number of regulators gave speeches or released papers and statements on supervision and regulation of crypto-assets, and we provide a quick summary of those statements as well. 

Speaking of suspense, we already know the ending of the LIBOR story: the required transition to an alternative rate by the June 30, 2023 deadline. Earlier this week, the Federal Reserve's Alternative Reference Rates Committee (the “ARRC”) published a “Playbook” to provide a roadmap for market participants in transitioning their legacy LIBOR contracts to an alternative rate ... in less than one year. This week, the head of our LIBOR transition team, Lary Stromfeld, explains some of the steps recommended by the ARRC for the successful implementation of fallbacks in legacy LIBOR contracts.

As always, we are very interested in hearing from you. Our market-leading, award-winning LIBOR transition team is ready and able to assist, and we're here to answer any questions about Cabinet News and Views or, more broadly, financial regulatory issues and challenges. 

Daniel Meade and Michael Sholem
Co-Editors, Cabinet News and Views

Partner | Financial Regulation

On July 11, the Alternative Reference Rates Committee (the “ARRC”) published a “Playbook” to assist market participants in transitioning their legacy LIBOR contracts to an alternative rate by June 30, 2023. The Playbook describes the steps that the ARRC recommends for the successful implementation of fallbacks in legacy LIBOR contracts.

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Partner | Financial Regulation

The last week has seen a number of announcements or statements from financial regulators calling for more oversight of crypto-assets, particularly stablecoins. 

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Partner | Financial Regulation

Yesterday, the full Senate confirmed Michael Barr to a four-year term as Vice Chair for Supervision and to Randal Quarles’ unexpired term as a member of the Board of Governors. That unexpired term as a member of the Board will run until January 2032. The vote for Mr. Barr’s confirmation was 66-28. 

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Partner | Financial Regulation
Counsel | Financial Services

In last week's Cabinet News and Views, we examined the U.S. regulators' approach to the digital asset space, with a focus on the assertion of jurisdiction by the CFTC, the SEC, prudential regulators, state executive and legislative branches, and Congressional initiatives. This week, our focus shifts to enforcement − what actions the various regulators are taking in the digital asset space and what we can expect to see in the near future.

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Cadwalader’s financial services team hosted Part 3 of its four-part series on capital relief trades yesterday.

You can access webinar replays here:

Registration details on Part 4 will follow.

Maurine R. Bartlett
Senior Counsel
T. +1 212 504 6218
maurine.bartlett@cwt.com

Brian Foster
Partner
T. +1 212 504 6736
brian.foster@cwt.com

James Frazier
Partner
T. +1 212 504 6963
james.frazier@cwt.com

Mark Howe
Partner
T. +1 202 862 2236
mark.howe@cwt.com

Gregg Jubin
Partner
T. +1 202 862 2485
gregg.jubin@cwt.com

Philip S. Khinda
Partner
T. +1 202 862 2262
philip.khinda@cwt.com

Ivan Loncar
Partner
T. +1 212 504 6339
ivan.loncar@cwt.com

Peter Y. Malyshev
Partner
T. +1 202 862 2474
peter.malyshev@cwt.com

Daniel Meade
Partner
T. +1 202 862 2294
daniel.meade@cwt.com

Jed Miller
Partner
T. +1 212 504 6821
jed.miller@cwt.com

Michael Newell
Partner
T. +44 0 20 7170 8540
michael.newell@cwt.com

Rachel Rodman
Partner
T. +1 202 862 2210
rachel.rodman@cwt.com

Richard M. Schetman
Senior Counsel
T. +1 212 504 6906
richard.schetman@cwt.com

Lary Stromfeld
Partner
T. +1 212 504 6291
lary.stromfeld@cwt.com

Jonathan M. Wainwright
Senior Counsel
T. +1 212 504 6122
jonathan.wainwright@cwt.com

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