Regulatory
Independent Expertise for Complex Regulatory Matters
Independent expert analysis of derivative and market risk for institutions, counsel and regulators facing complex regulatory inquiries, investigations and enforcement matters.
Our work combines hands-on experience in derivatives, trading, valuation and risk management with a practical understanding of regulatory expectations, market practice and financial institutions. CMRA has worked on both sides of the regulatory relationship, helping institutions assess and respond to regulatory concerns while also assisting regulators in understanding complex financial markets.
Market Expertise + Regulatory Context
Navigating Complexity Between Markets and Regulation
Complex regulatory matters often turn on how financial products, markets and institutions actually operate in practice.
CMRA combines experience in derivatives, trading, valuation and risk management with an understanding of regulatory concerns and market practice. This allows us to analyze highly technical issues in their proper financial and institutional context.
We translate complex market activity into clear, defensible analysis for regulators, counsel, boards and senior management.
Regulatory Services
Support Across Regulatory Matters
Independent derivative and market risk analysis across regulatory inquiries, internal investigations and reviews of risk-management and compliance frameworks.
Regulatory Inquiries
Analysis of complex financial activity in response to regulatory questions and concerns.
- Trading activity and market behavior
- Valuation, pricing and complex transactions
- Market practice, controls and risk management
Internal Investigations
Independent financial analysis supporting legal, compliance and senior management teams.
- Transaction and position reconstruction
- Risk, valuation and P&L analysis
- Fact development and control review
Compliance & Risk Review
Assessment of whether governance, controls and risk frameworks are appropriate for the institution and its activities.
- Policies, procedures and governance
- Valuation and risk-measurement frameworks
- Remediation and control enhancements
Specialized Regulatory Expertise
Market Manipulation Investigations
Allegations of manipulation often turn on how markets actually behaved at a specific moment in time.
Analysis of trading activity, price formation and market practice in matters involving benchmark rates, foreign-exchange fixes, securities auctions and financial-product settlement values.
Benchmarks & Fixes
ISDAFIX, LIBOR and foreign-exchange benchmark matters involving pricing, trading activity and market practice.
Auctions & Trading Activity
Treasury and corporate-bond auction allegations, transaction analysis and reconstruction of market conditions.
But-For & Damages Analysis
Assessment of market practice, damages and but-for price or valuation levels, including options settlement matters.
Our analysis combines quantitative evidence with an understanding of trading behavior, market structure and the economic context of the transactions at issue.
Explore Market Manipulation Expertise →Perspective Matters
Experience on Both Sides of the Table
Our regulatory work is informed by experience advising institutions and counsel as well as working directly with regulators on complex financial-market issues.
Institutions & Counsel
Understand the concern. Reconstruct the facts. Explain the market context.
CMRA helps institutions, boards and legal teams analyze trading, valuation, risk and market-practice issues and translate those findings into clear, defensible financial analysis.
Regulators
Explain the product. Analyze the activity. Clarify market practice.
CMRA has worked directly with regulatory and governmental bodies to explain complex products, trading behavior, valuation, market structure and institutional risk management.
That dual perspective helps identify the technical and market-practice issues most likely to matter in a regulatory review or investigation.
Selected Experience
Regulatory Experience in Practice
Much of CMRA’s regulatory and investigation work is confidential. The matters below include selected publicly disclosed engagements together with representative examples of the regulatory issues on which CMRA has advised institutions, counsel and regulators.
Long-Term Capital Management
CMRA advised the Federal Reserve Board of Governors on the risk-management implications of the Long-Term Capital Management crisis.
Bankers Trust
Participated in the comprehensive review of Bankers Trust’s derivatives business following regulatory scrutiny of its derivatives sales practices.
SEC Enforcement Matters
Served as an expert in multiple SEC enforcement actions involving complex financial products, market activity and related financial issues.
Federal Tax Court
Provided expert analysis, report and testimony involving a complex derivatives structure in federal tax court.
Representative Experience
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Regulatory Inquiries
Confidential matters involving derivatives, structured products, trading, valuation and risk management.
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Internal Investigations
Independent financial analysis, data review and fact development in support of legal and compliance teams.
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Risk & Compliance Reviews
Reviews of governance, controls, valuation and risk frameworks in connection with regulatory concerns and remediation.
Confidential engagements are described by institution type or matter type rather than by client name. Public matters are identified only where CMRA’s involvement has previously been disclosed.
Regulatory Insights
Recent Regulatory Developments
CMRA follows regulatory developments affecting derivatives, risk management, collateral, valuation, financial institutions and complex capital markets.