• Posts by Tiffany E. Payne
    Counsel

    Tiffany’s practice focuses on white collar and government enforcement defense matters, internal investigations, and regulatory advice and compliance. She proactively counsels clients through complex regulatory ...

On November 3, 2025, IOSCO released its anticipated Pre-Hedging Final Report (“Final Report”) detailing its assessment of current pre-hedging market practices and setting out recommended guidance for International Organization of Securities Commissions’ (“IOSCO”) members. The intended purpose of the Final Report is “to facilitate greater consistency and clarity around pre-hedging, and to promote a level playing field for all participants across jurisdictions, asset classes and execution types.” IOSCO initiated its multi-step assessment process in June 2023. IOSCO is the international body that brings together markets regulators to establish standards and provide guidance to its members. Both the U.S. Securities Exchange Commission and the U.S. Commodity Futures Trading Commission are members and sit on the IOSCO board.

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