Nihal Patel @nihal_s_patel
Writes about law, financial regulation, and other things. Also, a lawyer. Views expressed (and errors made) are mine alone and not Fried Frank’s. New York, NY Joined February 2017-
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Notable relief, particularly given that the existing rule really had no materiality concept in the notice. It does raise questions to consider such as how to treat these errors for general compliance and self-reporting purposes.
Notable relief, particularly given that the existing rule really had no materiality concept in the notice. It does raise questions to consider such as how to treat these errors for general compliance and self-reporting purposes.
The section of the swap adopting release on FX products is one of the more confusing interpretations around. Further color and discussion on these products is positive.
The section of the swap adopting release on FX products is one of the more confusing interpretations around. Further color and discussion on these products is positive.
Practical effect is that they are reading this part out of the rule until if and when they decide to go through an actual rulemaking process to get rid of it.
Practical effect is that they are reading this part out of the rule until if and when they decide to go through an actual rulemaking process to get rid of it.
the withdrawn letter (21-19) wasn’t great policy or the result of great process (ad hoc staff statement), but withdrawing it with very little comment comment isn’t ideal either; market participants deserve explanations of the reasoning behind shifts in policy
the withdrawn letter (21-19) wasn’t great policy or the result of great process (ad hoc staff statement), but withdrawing it with very little comment comment isn’t ideal either; market participants deserve explanations of the reasoning behind shifts in policy
In other words: we’re not responsible for it, but that doesn’t mean it’s good for you.
In other words: we’re not responsible for it, but that doesn’t mean it’s good for you.
Be so great at what you do that you can die a decade after your retirement at age 95 and it will still feel like an unspeakable loss.
1 year delay for Treasury clearing not so surprising. will be more interesting to see if rule sticks in general under the new leadership. nb the acting chair voted for the mandate (but pierce dissented) sec.gov/newsroom/press…
The @SECGov sent me an interesting comment on the dropping of the agency's crypto dealer-rule appeal: "... Continuing to pursue it had the risk of reducing liquidity in the Treasury markets, making them more volatile, and increasing debt for taxpayers." coindesk.com/policy/2025/02…
IS EVERYTHING LEGAL, OR…? Join me for a free webinar on Tuesday March 4 at 3 PM ET, where I’ll chat with my partners Ilan Graff and Nihal Patel about crypto litigation and regulatory predictions for 2025 and beyond. Please pre-register. Link in post below.
Subtle but potentially very significant change in the form of a staff faq.
Subtle but potentially very significant change in the form of a staff faq.
Enjoyed talking to @wilkkes on this one.
I wrote about “swaps” and “SBS” and the SEC and CFTC disagreeing about what’s what. findknowdo.com/news/10/02/202…
Partner Nihal Patel was quoted in a @WSJ article about a trader accused by federal authorities of manipulating prices on a #crypto exchange and withdrawing $100+ million from the platform. Read more here: bit.ly/FFMM203
Crypto exchange Mango Markets all but collapsed after a 27-year-old trader withdrew millions from the platform, authorities say. Avraham Eisenberg says he did only what Mango’s software code made possible. on.wsj.com/3Z1yLai
The SEC recently charged an individual engaging in a #crypto token manipulation scheme. Read more in the latest Fried Frank Regulatory Intelligence article below, with commentary from partner Nihal Patel: bit.ly/FFRI_18 #FFRI
Excellent commentary by my partner Nihal on the Avi Eisenberg suit. findknowdo.com/news/01/20/202…
Wrote a bit about the MNGO crypto thing and the security/commodity jurisdictional divide. findknowdo.com/news/01/11/202…
I wrote a bit about the CFTC regulatory agenda. findknowdo.com/news/01/10/202…
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