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February 03, 2014

In three separate letters, SIFMA and six other financial industry associations filed comments with the Office of the Comptroller of the Currency ("OCC"), the Board of Governors of the Federal Reserve System ("FRB") and the Federal Deposit Insurance Corporation ("FDIC") (collectively, the "Federal Agencies") on the proposed rules regarding the liquidity coverage ratio ("LCR"). The letters contained comments on the LCR proposal in connection with international standards, securitization and municipal securities. In the first letter (linked below), SIFMA, the Structured Finance Industry Group (

September 25, 2015

The Board of Governors of the Federal Reserve System added two additional questions and answers to its Volcker Rule FAQs. New question number seventeen deals with compliance procedures for market making desks and the identification of covered funds. New question number eighteen discusses CEO certification for prime brokerage transactions.

September 29, 2015

The Board of Governors of the Federal Reserve System ("FRB") Associate Director of Banking Supervision and Regulation Thomas Sullivan stated that the FRB is constructing a domestic regulatory capital framework for its supervised insurance holding companies that is "well tailored to the business of insurance." The development of the framework stems from Congress's enactment of the Insurance Capital Standards Clarification Act of 2014 (S. 2270). This Act amended the Dodd-Frank Act provision that previously had required the minimum capital standards to be applied to any insurance holding company

October 28, 2015
Commentary by Steven Lofchie

In a paper titled "The Best Execution of Corporate Bonds," Cornell University Finance Professor Maureen O'Hara, Fordham University Business Professor Yihui Wang and Board of Governors of the Federal Reserve System Economist Xing Zhou provide "strong evidence of best execution failures in corporate bond trading." Using an "extensive sample" of bond trades by insurance companies, the paper found that (i) an insurance company entering a trade of similar size and on the same side for the same bond on the same day with the same dealer will receive a better price if it is more active as an investor

November 17, 2015
Commentary by Steven Lofchie

Pursuant to the authority granted by Title VIII (Payment, Clearing and Settlement Supervision) of the Dodd-Frank Act, the Board of Governors of the Federal Reserve (FRB) requested comments on its proposal to use the rating system known as ORSOM (Organization; Risk Management; Settlement; Operational Risk and Information Technology; and Market Support, Access, and Transparency) to review financial market infrastructures (FMIs). The FRB specified that: the ORSOM rating system is a supervisory tool that the Federal Reserve will use to provide a consistent internal framework for discussing FMI