Download Financial Services & Public Policy Alert June 2009

Financial Services & Public Policy Alert
June 2009
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The Obama Plan for Financial Services
Regulatory Reform: A New Foundation or An
Ambitious Renovation?
The Obama Administration unveiled the much-anticipated proposal for reforming
how the financial services industry is regulated on June 17, 2009. When enacted,
these reforms, which are billed as “a new foundation for financial regulation and
supervision,” will have significant consequences for the financial services industry.
However, rather than the comprehensive restructuring of the current patchwork
regulatory framework that has been recommended by commentators in recent
months, the proposal aims to fill regulatory gaps by granting new powers to existing
regulators and creating new regulators. These reforms will have impact across the
full spectrum of capital markets issues. Therefore, many K&L Gates partners
working together in an interdisciplinary Capital Markets Reform Group have
provided their insights for this alert.
Overview of the Obama Administration Proposal
In summary, the proposal would:
•
Grant the Board of Governors of the Federal Reserve System (“Federal
Reserve”) the power to supervise all large financial institutions that pose
systemic risk, even those that do not own banks. These large, interconnected
firms (Tier 1 financial holding companies or “Tier 1 FHCs”) as well as their
parents and subsidiaries would be subject to heightened capital, liquidity, and
risk management standards. The Federal Reserve would also gain the power to
supervise systemically important payment, clearing, and settlement systems.
•
Create a new Financial Services Oversight Council (“Council”) having the
power to gather information from any financial firm in order to identify
emerging systemic risks. In addition, the proposal would provide the
Department of Treasury (“Treasury”) with resolution authority over non-bank
financial institutions that pose systemic risk.
•
Consolidate the Office of the Comptroller of the Currency (“OCC”) and the
Office of Thrift Supervision (“OTS”) into a single regulator, the National Bank
Supervisor (“NBS”), eliminate the federal thrift charter, and remove obstacles to
interstate branching by national and state banks.
•
Create a new Consumer Financial Protection Agency (“CFPA”) to regulate all
financial products and services and the institutions that provide them. It would
be an independent agency with rulemaking, supervisory, examination, and
enforcement authority under fair lending and consumer financial protection laws.
The CFPA would require that disclosure forms are clear and that consumers
were offered simple and fair financial products.
Financial Services & Public Policy Alert
•
Require advisers to hedge funds and private
pools of capital to register with the Securities
and Exchange Commission (“SEC”) and impose
recordkeeping, disclosure, and reporting
requirements on the funds they advise.
•
Keep the Commodity Futures Trading
Commission (“CFTC”) and SEC as separate
entities, but harmonize the regulation of futures
and securities by creating uniform principles of
regulation, and subject all over-the-counter
(“OTC”) derivatives to comprehensive
regulation.
•
Address the breakdown of the securitization
markets by requiring loan originators to retain a
five percent interest in the risk of securitized
credit exposures, imposing reporting
requirements on issuers of asset-backed
securities, and reducing regulator reliance on
credit rating agencies.
•
Establish an Office of National Insurance
(“ONI”) within the Treasury to gather
information and coordinate policy in the
insurance sector.
•
Encourage the SEC to reform the money market
fund industry, in consultation with the
President’s Working Group on Financial
Markets.
Context of Proposal
The proposed reforms would have a significant
impact on the financial services industry. The
Administration’s proposal, however, is more
moderate than many expected, particularly in the
context of recent financial services reform literature
which has trended towards recommending
increasingly more extensive regulatory restructuring.
Preliminary reports, such as the U.S. Chamber of
Commerce Commission on the Regulation of U.S.
Capital Markets in the 21st Century Report and the
Bloomberg/Schumer Sustaining New York’s and the
US’ Global Financial Services Leadership Report,
had recommended some level of modernization to
address the overlaps and gaps in the current financial
markets regulatory system. Released in March
2008, the Department of Treasury Blueprint for a
Modernized Financial Regulatory Structure, among
other things, significantly called for the merger of
the CFTC and the SEC, which the Administration
did not propose.
On January 15, 2009, the Group of Thirty issued a
report entitled Financial Reform: A Framework for
Financial Stability. The report, primarily authored
by former Federal Reserve Chairman Paul Volcker,
one of President Obama’s economic advisors and
Chairman of the President’s Economic Recovery
Advisory Board, recommended a massive, globally
coordinated restructuring of the legislative and
regulatory system that governs the financial services
industry (see K&L Gates Alert Group of Thirty
Issues Roadmap for Financial Reforms). On May
26, 2009, the Committee on Capital Markets
Regulation released The Global Financial Crisis: A
Plan for Regulatory Reform. The Committee
recommended creating a new agency, similar to the
U.K.’s Financial Services Authority, to regulate all
aspects of the financial system.
The relatively moderate approach taken by the
Administration provides important insights into the
development of the proposal and the road ahead.
The Administration’s proposal was developed with
a significant amount of input from key Members of
Congress, including House Financial Services
Chairman Barney Frank (D-MA) and Senate
Banking Committee Chairman Chris Dodd (D-CT),
and other stakeholders. As such, the
Administration’s proposal largely represents a
consensus on the general form the financial services
reforms should take.
However, the Administration’s approach may pose
strategic and political difficulties moving forward.
In the legislative process, concessions are essential
to negotiation. In recognition of this, legislative
proposals often contain controversial but extraneous
provisions which are “given up” in order to gain the
support of key interest groups, eventually ending
with the desired outcome. By making relatively
moderate proposals, it is not clear how close the
final enactment will be to the desired form. At
present, the key targets include empowering the
Federal Reserve as the systemic risk regulator and
the proposed CFPA, recommendations which
interest groups have criticized in the days since the
proposal’s release.
Regulation of Systemic Risk
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Financial Services & Public Policy Alert
The proposal recommends creating a Financial
Services Oversight Council, a concept similar to the
one proposed by the Federal Deposit Insurance
Corporation (“FDIC”) Chairman Sheila Bair and
SEC Chairman Mary Schapiro. The Council would
consist of various Administration officials, to
facilitate information sharing and coordination,
identify emerging risks, advise the Federal Reserve
on systemic risk, and resolve jurisdictional disputes
between regulators. The proposal would provide the
Federal Reserve with the authority to designate and
supervise any systemically significant financial
institutions as Tier 1 FHCs, without regard to
whether such organizations control depository
institutions. Although any proposed legislation
would include parameters for the Federal Reserve to
use when making such a designation, this proposal
still represents unprecedented authority for a
regulator to deem an organization subject to a new
regulatory regime.
The Tier 1 FHCs would be subject to an even greater
level of scrutiny, including stringent capital and
prudential requirements. Moreover, consolidated
supervision of the Tier 1 FHCs would extend to their
parents and subsidiaries, whether regulated or
unregulated, U.S. or foreign domiciled. This could
lead to a competitive imbalance, where market
participants interpret the heightened supervision and
oversight of these entities as making them safer than
non-Tier 1 FHCs.
Depository Institutions
The proposal recommends reforming regulation and
supervision of banks and thrifts by eliminating the
OTS and consolidating supervision and regulation of
national banks and federal thrifts under a new
regulator, the NBS. Although the proposal is
unclear on this point, it appears that the NBS would
essentially be a reconstituted OCC. The proposal
does not address the issue of which regulator would
regulate state savings banks currently regulated by
the OTS. The FDIC would remain the regulator of
state non-member banks, while the Federal Reserve
would be the regulator for state member banks.
Thus, the proposal leaves in place the nation’s dual
banking system, although it promises to blur the
distinctions between the various charters to avoid
regulator shopping. Similarly, the authority of the
National Credit Union Administration to regulate
credit unions would remain unchanged.
Holding company supervision would also be
consolidated into a single regulator, the Federal
Reserve. Thus, the former distinctions between
thrift holding companies and bank holding
companies are proposed to be eliminated. The
proposal would also eliminate all exceptions to the
definition of “bank” for purposes of determining
which companies are subject to bank holding
company regulation, forcing all commercial firms
that currently operate banks to cease doing so. This
includes industrial loan companies, unitary thrift
holding companies, and even retailers that operate
credit card banks, many of which played little role
in the financial crisis. Trust companies that have
FDIC-insured deposits would also be considered
banks for bank holding company purposes, but the
proposal is silent on the status of trust companies
that do not accept FDIC-insured deposits.
In addition, all bank holding companies would be
subject to capital and prudential requirements more
stringent than those currently in place, and Tier 1
FHCs would be subject to an even greater level of
scrutiny. The proposal also echoes prior proposals
that call for granting the Treasury, FDIC, and
Federal Reserve new resolution powers over
systemically significant financial organizations.
Consumer Financial Protection
Agency
The proposal recommends the creation of the
CFPA, a new federal agency responsible for
protecting consumers in the financial products and
services markets. The concept of the CFPA was
first proposed by Elizabeth Warren, the chair of the
TARP Congressional Oversight Panel, and has
gained momentum among policymakers in recent
months (see K&L Gates Alert Fifty Ways to Need a
Lawyer: Congress Proposes to Establish Financial
Services Watchdog Agency and the upcoming K&L
Gates Alert on the proposed CFPA).
Characterizing the current regulatory regime as
“fragmented,” the CFPA would have extensive
regulatory, supervisory, and enforcement authority
over all financial products and services providers,
except for those investment products and services
that the SEC or CFTC already regulates. The
proposal calls for providing the CFPA with
exclusive authority to promulgate and interpret
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Financial Services & Public Policy Alert
regulations under existing and future consumer
financial services and fair lending statutes,
suggesting that the authority of existing federal
financial regulators would be scaled back to some
extent. In addition, the new agency would have the
authority to ban unfair and deceptive acts and
practices.
would provide to the Federal Reserve to assess
whether the fund or fund complex is so large, highly
leveraged, or interconnected as to pose a threat to
financial stability. Such firms, deemed “Tier 1
FHCs,” would be subject to, among other things,
higher capital, liquidity, and risk management
standards.
Under the proposal, the CFPA would do it all, from
requiring mortgage companies to offer a
straightforward “plain vanilla” mortgage product, to
enforcing fair lending laws and the Community
Reinvestment Act, to requiring a duty of
“reasonableness” in communications and
transparency in mortgage loan disclosures. In fact,
there is hardly any area of financial regulation that
the CFPA would not affect. Although the depth and
breadth of the agency’s proposed authority and
responsibilities makes it unlikely that all of the
recommendations will actually become law, it is
indicative of the clear appetite for a new consumer
protection regime.
If implemented, these initiatives could have a farreaching impact on the managers of private pools of
capital. For example, these initiatives could require
U.S. and non-U.S. domiciled advisers to certain
non-U.S. domiciled private investment funds to
register under the Advisers Act. Non-U.S.
domiciled advisers to non-U.S. domiciled funds
could be subject to these requirements, if such funds
themselves rely on an exemption from registration
under the Company Act. Also, if a U.S. or non-U.S.
domiciled adviser (which shares personnel and
obtains other services from non-U.S. regulated
affiliates) registers under the Advisers Act, then the
issue would be presented as to the extent to which
the requirements of the Advisers Act would apply to
the non-U.S. operations, clients or accounts
managed or serviced by such non-U.S. regulated
affiliates.
Private Investment Fund Advisers
The proposal recommends that advisers to hedge
funds and other private pools of capital, including
advisers to private equity funds and venture capital
funds, whose assets under management exceed some
unspecified “modest” threshold, be required to
register with the SEC under the Investment Advisers
Act of 1940 (“Advisers Act”). Although not
specified in the proposal, “private pools of capital”
are likely to be identified in draft implementing
legislation as including investment funds that rely
upon the exemptions from registration under the
Investment Company Act of 1940 (“Company Act”)
provided by Sections 3(c)(1) and 3(c)(7) thereunder.
It is of interest that the proposal does not call for the
outright elimination of the “private adviser
exemption” under Section 203(b)(3) of the Advisers
Act as some have suggested.
Private investment funds managed by these SECregistered advisers would be subject to regulatory
reporting requirements, recordkeeping requirements,
and mandatory disclosure obligations to investors,
creditors, and counterparties. The proposal would
require the investment funds to report on a
confidential basis the amount of assets under
management, borrowings, off-balance sheet
exposures, and other information that the SEC
The proposal also emphasizes the need for
international regulation of hedge funds and calls for
the global implementation of the G-20 commitments
for registration of hedge funds (or their managers)
and enhanced disclosure requirements.
Securitization
Transparency and Credit Ratings
The proposal strives to bring the securitization
markets into a coherent regulatory framework in
order to improve transparency and market
discipline. These efforts include initiatives to
improve and standardize disclosure practices by
originators, underwriters, and credit rating agencies.
New requirements would help ensure that investors
and credit rating agencies have access to more
information about the assets underlying a
securitization transaction. In particular, issuers of
asset-backed securities (“ABS”) would be required
to disclose loan-level data, broken down by loan
broker or originator.
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Financial Services & Public Policy Alert
In addition, the SEC would have clear authority to
require robust, ongoing reporting by ABS issuers.
Under current law, a registered offering of ABS
triggers a reporting obligation, but the reporting
obligation is normally suspended because of an
exception in the law. Implementing the proposal
may involve limiting or eliminating that exception.
With respect to secondary market trading, the Trade
Reporting and Compliance Engine (also known as
“TRACE”), the standard electronic trade reporting
database for corporate bonds, would include ABS.
This would enhance price discovery, but it may
impair liquidity and the willingness of financial
intermediaries to make a market in certain ABS.
The proposal also calls for strengthening the
regulation of credit rating agencies. Credit rating
agencies would be required to have robust policies
and procedures that manage and disclose conflicts of
interest, differentiate between structured and other
products, and otherwise promote the integrity of the
ratings process. Regulators would also be required
to reduce their reliance on credit ratings in
regulations and supervisory practices. Such a
change would impact net capital rules for brokerdealers, risk-based capital requirements for banks,
eligibility requirements for securities that can be
owned by money market mutual funds, and
eligibility to register certain debt securities using a
shelf registration statement. To the extent risk-based
regulatory capital rules would continue to rely on
credit ratings, those rules would account for the risk
of structured credit products, including the
concentrated systematic risk of senior tranches and
re-securitizations and the risk of exposures held in
highly leveraged off-balance sheet vehicles. These
changes would be closely tied to the proposed
increases in regulatory capital requirements on
highly rated ABS.
While significant new legislation will be required to
implement some of the proposal’s securitization
changes, most of the proposal depends on the
continuation of existing regulatory and industry
initiatives and, in some cases, changes to accounting
rules.
Realigning Risks
The proposal lays some of the responsibility for the
financial crisis on securitization because, by
breaking the link between borrowers and lenders, it
contributed to an erosion of lending standards that
resulted in a market failure. The proposed solution
is to require loan originators or sponsors to retain
five percent of the credit risk of securitized
exposures, which they would not be able to hedge.
This requirement may effectively prevent non-bank
mortgage bankers from providing housing credit,
which currently benefits consumers by providing
competition to banks. Such mortgage bankers
generally do not have capitalization to permit
retaining significant securitization risk on their
balance sheets, and raising additional equity capital
in the current markets would be difficult. With
respect to banks, the proposal leaves it to the federal
banking agencies to apply the retention requirement
to securitization sponsors rather than loan
originators. At a time when the industry and the
Administration acknowledge the need to restart
securitizations, this retention requirement may
further slow recovery in the securitization market.
Additional proposed regulations would align the
compensation of market participants with the longterm performance of the loans underlying
securitization transactions. Much work will need to
be done to find fair and sensible ways to limit, or
claw back, compensation based on poor
performance of the loans. It may often be difficult
to determine whether poor performance is
attributable to a change in market conditions,
changed borrower circumstances, or just poor
underwriting. Given the range of participants in the
process, from loan brokers to originators to
securities firms, each with its own compensation
conventions and structures and many subject to
different regulatory regimes, developing consistent
standards and approaches on this issue may prove
difficult.
Commodities, Futures, and
Derivatives
As expected, the CFTC would not be merged into
the SEC, but the proposal does call for harmonizing
how the two agencies regulate. Specifically, the
CFTC and SEC would build a common foundation
for market regulation by agreeing on principles that
are significantly more precise than the current “core
principles” that were enacted by the Commodity
Futures Modernization Act of 2000 (see upcoming
K&L Gates Alert Can We All Get Along? –
June 2009
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Financial Services & Public Policy Alert
Administration Urges Futures and Securities
Harmonization).
The proposal offers few, if any, details of how
CFTC and SEC regulation might reach a state of
harmonic nirvana. The CFTC and SEC are to
complete a report to Congress by September 30,
2009 identifying conflicts and recommending how
to eliminate them. If they cannot agree, remaining
disputes will be referred to the Council, which will
have 6 months to report its recommendations to
Congress. Conflicts yet to be sorted out include
identifying which products each agency would
regulate; determining how to treat derivatives related
to debt or equity instruments or various economic
indices, which are now deemed to be “excluded
commodities”; regulating hedge fund advisers
currently registered with the CFTC as commodity
pool operators or commodity trading advisers; and
imposing fiduciary duties on broker-dealers and
futures commission merchants.
The proposal also recommends that all OTC
derivatives, including credit default swaps, would be
subjected to comprehensive regulation.
Standardized OTC derivatives would be transacted
on regulated exchanges and transparent electronic
trading systems, and cleared through regulated
central counterparties. For customized OTC
derivatives that could not be cleared and exchangetraded, regulatory requirements applicable to all
dealers and other firms would provide the functional
equivalent of clearing and minimize systemic risk.
These regulations would include promptly reporting
all transactions to a regulated trade repository and
maintaining conservative capital, margin, and
business conduct requirements. The capital
requirements would be more conservative than
existing bank capital regulatory requirements related
to OTC derivatives.
Market efficiency and transparency would be
improved by creating a system to disseminate
promptly prices and other trade information.
Aggregate volume and open position data would be
publicly available, and data on a particular party’s
transactions and positions would be available to
regulators on a confidential basis.
Broker-Dealers
The proposal includes establishing a fiduciary duty
for broker-dealers offering investment advice and
harmonizing the regulation of investment advisers
and broker-dealers. Among other things, new
legislation would “bring important consistency” to
the regulation of broker-dealers and investment
advisers by requiring broker-dealers who provide
investment advice to investors to have the same
fiduciary obligations as registered investment
advisers. The proposal would also prohibit certain
conflicts of interest and sales practices that are
contrary to the interests of investors.
While the proposal speaks of “retail” investors, it is
unclear whether firms will be held to this higher
fiduciary standard for their institutional clients.
Similarly, it is unclear whether dealers that offer
several securities for an investor to consider,
particularly in the context of fixed income principal
trading, will be subject to the traditional suitability
standard or will owe a fiduciary duty. One possible
effect of this broad expansion of responsibility is a
higher cost to investors to account for the increased
litigation exposure.
The proposal also reopens the examination of the
differences between the regulation of broker-dealers
and investment advisers and the distinct relationship
each has with its clients. The definition of
“investment adviser” in the Advisers Act excludes
“any broker or dealer whose performance of such
services is solely incidental to the conduct of his
business as a broker or dealer and who receives no
special compensation.” As recently as 2005, the
SEC issued rules that set forth criteria for
determining when advice provided by a brokerdealer should not be deemed to be “solely
incidental” to its brokerage services. Expect those
regulations to be reconsidered as the proposal works
its way into law.
Insurance Markets
The proposal’s treatment of the insurance industry
is paradoxical. It laments the weaknesses of
regulating insurance at the state level and indicates a
strong preference for federal regulation of
insurance, but it fails to call for an end to state
regulation in whole or in part. Instead, it proposes
to create the ONI within Treasury, which would
have the power to gather information, identify
weaknesses, and coordinate policy throughout the
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Financial Services & Public Policy Alert
insurance industry. The ONI would also have the
power to negotiate international agreements and
“speak with one voice” on behalf of the U.S.
insurance industry.
Despite the proposal’s lofty goal of developing a
modern regulatory framework for insurance, the
proposed ONI is charged only with understanding
and monitoring the insurance industry. Its powers
would be limited to encouraging states to increase
capital standards and reduce regulatory
inconsistencies. A main purpose of the ONI would
be to recommend that the Federal Reserve regulate
specific insurance companies as Tier 1 FHCs. The
ONI also would be given authority in the
international context to represent the U.S. in the
International Association of Insurance Supervisors,
enter into international agreements, and increase
international cooperation on insurance regulation.
In addition, insurance products that would be
considered investment products, such as annuities
that are not already regulated by the SEC or CFTC,
would be subject to regulation by the proposed
Consumer Financial Protection Agency.
Money Market Funds
The proposal shows an appetite for potentially major
reforms to money market fund regulations in order
to reduce “the susceptibility of money market
mutual funds to runs,” as illustrated by the impact of
the Reserve Primary Fund’s net asset value falling
below $1.00 per share in September of 2008. The
proposal encourages the SEC to move forward with
plans to require substantial liquidity buffers, reduce
the weighted average maturity of securities held,
tighten credit concentration limits, improve risk
analysis and management, and empower boards of
directors to suspend redemptions in extraordinary
circumstances.
In addition, the President’s Working Group on
Financial Markets would be required to prepare a
report assessing whether more fundamental changes
are necessary. The report, which would be due
September 15, 2009, would consider eliminating the
stable net asset value and requiring money market
funds to access emergency liquidity facilities from
private sources. Any new regulations would require
approval by the SEC and would involve a waiting
period during which the SEC may consider
comments on the proposed regulations. In March,
SEC Chairman Mary Schapiro stated that the SEC
was considering similar reforms to strengthen fund
credit quality, maturity, and liquidity standards in
remarks before the Senate Banking Committee; one
of the SEC’s proposals includes a floating net asset
value.
International Financial Markets
Extending beyond the U.S. financial system, the
proposal calls upon the U.S. to use its leadership to
raise international regulatory standards and improve
international cooperation. The coordination would
involve improving the Basel II capital standards,
supervising internationally active firms, aligning
crisis management efforts, and strengthening
financial regulation in all countries. With more
consistent supervision, financial institutions would
be less likely to move their activities to those
jurisdictions that have weaker standards.
The proposal sets a laudable goal, but does not
provide clear answers as to how it could be reached.
Achieving worldwide consensus to raise
international regulatory standards and improve
international cooperation would be an incredibly
difficult task. Efforts to coordinate financial
regulation internationally are limited by the fact that
so few countries participate and those that do
participate are not bound to implement specific
recommendations. As illustrated by the European
Union, even when nations implement common
international standards, the result can vary so much
from one country to another that it is hard to fathom
that the final legislation was derived from the same
standard.
The Next Steps
Chairman Barney Frank is expected to pursue
financial services legislation in the near term. The
House was initially expected to finish its
consideration of the legislation by August, but that
time frame has already begun to slow. The House
Financial Services Committee will now be holding
hearings, committee meetings, and markups on
financial regulatory reform into September.
The pace of the Senate action is also unclear,
partially due to Chairman Dodd’s current focus on
health care reform, which is also a priority for the
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Financial Services & Public Policy Alert
White House. (The House and Senate will likely
vote on their respective health care reform bills
before the August recess; a conference is expected to
follow in late September or early October).
Chairman Dodd had stated that he intends to move
forward with financial services legislation, but has
indicated that he expects lengthy deliberations. It
has been suggested that the Senate may take up the
legislation in late September, with the goal of having
it to the President by early 2010. However, it is
likely that the process could continue well into next
year.
of designated partners in each of the firm’s relevant
practice areas across the full spectrum of capital
markets issues. These practice areas include:
broker-dealer and securities trading; commodities
and futures; depository institutions; derivatives and
securitization; hedge funds; insurance and annuities;
investment banking; investment management;
mortgage banking and consumer finance; and public
policy. By coordinating across all of these
disciplines, K&L Gates will be able to provide
unequaled service and insights to firm clients as
these new laws and implementing regulations are
written.
As mentioned above, K&L Gates has established an
internal Capital Markets Reform Group that consists
June 2009
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Financial Services & Public Policy Alert
For more information on K&L Gates’ Capital Markets Reform Group, please contact one of the
professionals listed below.
Insurance/Annuities
Diane E. Ambler
[email protected]
+1.202.778.9886
Investment Banking
Philip M. Cedar
[email protected]
+1.212.536.4820
Public Policy & Law
Daniel F. C. Crowley
[email protected]
+1.202.778.9447
European Regulation
Vanessa C. Edwards
[email protected]
+44.(0)20.7360.8293
Broker-Dealer/Securities Trading
Edward G. Eisert
[email protected]
+1.212.536.3905
Mortgage Banking & Consumer Financial Products
Steven M. Kaplan
[email protected]
+1.202.778.9204
Depository Institutions
Sean P. Mahoney
[email protected]
+1.617.261.3202
Hedge Funds
J. Matthew Mangan
[email protected]
+1.415.249.1046
European Financial Services
Philip J. Morgan
[email protected]
+44.(0)20.7360.8123
Investment Management
Mary C. Moynihan
+1.202.778.9058
[email protected]
Derivatives/Securitization
Anthony R.G. Nolan
[email protected]
+1.212.536.4843
Money Market Funds
Clair E. Pagnano
[email protected]
+1.617.261.3246
Commodities/Futures
Lawrence B. Patent
[email protected]
+1.202.778.9219
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Financial Services & Public Policy Alert
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June 2009