Michael Dawson
- Indexed articles, last 90 days
- 5
- Latest publication
- Sep 17, 2026
- Outlet visibility, for Mondaq
- Top 500K sites
- Earliest in this view
- Jul 13, 2026
Latest articles
U.S. Senate Falls Short On Procedural Vote To Advance The Digital Asset Market Clarity Act (opens the original)
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On September 15, 2026, the Senate voted on a motion to proceed to consider the Clarity Act but failed to achieve the 60-vote threshold necessary to proceed to debate. It is unclear at this time when the Senate will move to reconsider the vote or if additional changes will be made to the legislation prior to a follow-up procedural vote. The Clarity Act, a version of which passed the House of Representatives in July 2025, would establish the first comprehensive federal regulatory framework for dig
Recordkeeping In The Blockchain Era: SEC Proposes Overhaul To The Transfer Agent Rules (opens the original)
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The Situation: On September 1, 2026, the Securities and Exchange Commission (the "SEC") proposed a comprehensive modernization of the federal rules governing registered transfer agents under Release No. 34-106246 (the "Proposal"), the first substantive rewrite of these rules since their adoption in the late 1970s and early 1980s. The Change: The Proposal adopts technology-neutral language that would expressly permit transfer agents to use distributed ledger technology ("DLT"), including blockcha
Final OCC/FDIC Rule Provides Greater Transparency And Consistency For Supervisory And Enforcement Activities (opens the original)
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The Situation: On August 27, 2026, the Office of the Comptroller of the Currency ("OCC") and the Federal Deposit Insurance Corporation ("FDIC") issued a final rule that for the first time defines the term "unsafe or unsound practice" for purposes of the agencies' supervisory and enforcement activities. In connection with the final rule, the OCC also substantially revised its policies and procedures manual ("PPM") on enforcement actions and publicly released for the first time the PPM covering ma
U.S. Treasury Proposes GENIUS Act Rules For Stablecoin Issuance, Offer, And Sale (opens the original)
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The Situation: On August 18, 2026, the U.S. Department of the Treasury ("Treasury") issued a notice of proposed rulemaking ("NPRM") related to section 3 of the Guiding and Establishing National Innovation for U.S. Stablecoins Act ("GENIUS Act"). The Change: Once finalized, the proposed rulemaking would establish: (i) the scope and definitions of the proposed regulation; (ii) a requirement to issue payment stablecoins in the United States only as permitted under the GENIUS Act; (iii) a requiremen
From Rigid Routing To Best Execution: SEC Proposal Could Reshape Listed Equities And On-Chain Markets (opens the original)
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The Situation: On June 11, 2026, the Securities and Exchange Commission (the "SEC") proposed the rescission of Rule 611 (the trade-through prohibition) and Rule 610(e) (the locked and crossed markets prohibitions) of Regulation NMS. The Change: By eliminating the restrictive market structure rules, the SEC would remove a traditional backstop and instead rely on competitive market forces and broker-dealers' existing best execution obligations under FINRA Rule 5310 to govern order handling in the
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