Risk and regulatory consulting

Helping you achieve your strategic goals in an environment of evolving risks and constant regulatory change.



policyOS: Policy as the Operating System for Business

policyOS: Policy as the Operating System for Business

As technology companies mature and begin engaging with policy makers, it's important to understand how policy affects their businesses using their own terms. As they develop apps that work on top of a device's operating system, their businesses work on top of a policy operating system with code written by legislators, regulators, and other public officials. In order to enhance the capabilities of their business, they need their policy "engineers" to help enhance "policyOS" so that their technologies can reach their full potential for users everywhere.

Broker-dealers: New FAQs on TBAs

Broker-dealers: New FAQs on TBAs

"On September 15, the Financial Industry Regulatory Authority (FINRA) published a set of Frequently Asked Questions (FAQs) on FINRA rule 4210. The Rule requires broker-dealers to collect margin on the majority of To-Be-Announced (TBA) transactions due to the counterparty credit risk exposure broker-dealers face as a result of the transactions’ long settlement durations. The FAQs provide clarity around several areas of the Rule, including its treatment of net capital deductions, customer protection, and margin. Most notably, the FAQs extended the Rule’s compliance date for these requirements, the second of two compliance phases, from December 15, 2017 to June 25, 2018. This is welcome news to the industry as these requirements will require large system updates and new customer documentation. This regulatory brief provides an analysis of key concepts included in the FAQs and what we view as the primary implementation challenges"

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David Sapin

US Risk and Regulatory Consulting Leader




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David Sapin
Principal, Risk and Regulatory
Tel: +1 (202) 756 1737