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Financial Services Authority October 25, 2011 The FSA has fined Credit Suisse UK pound;5.95 million for systems and controls failings in relation to sales by its private bank of structured capital at risk products (" SCARPs "). Concerns were identified by the FSA during a supervisory visit to the firm, which subsequently led to the FSA commencing its enforcement investigation. The FSA found that Credit Suisse UK had poor systems and controls in place and failed to maintain adequate records regarding its advice on these products. These failings amounted to a breach of Principle 3 (FSA Handbook

The National Futures Association ("NFA") announced changes to CPO Form PQR and CTA Form PR based on feedback received from CPO/CTA Members. The changes, according to the NFA, are intended to simplify and make less burdensome the Forms' questions relating to the NFA's request for information relating to any funds under management allocated to futures and swaps. A few questions have been deleted and more help with certain questions has been provided. The changes will become effective on June 30, 2014, with updated Forms available on the Easy File System on the first week of July 2014. See: NFA

Conyers Dill Pearman issued a client alert regarding the Contracts (Rights of Third Parties) Law ("the Law"). The Law, which was published and became immediately effective on May 21, 2014, allows for the enforcement of contractual rights by a third party. Additionally, the Law permits a variation in the preexisting position under Cayman Islands law based upon the common law doctrine of privity of contract. The alert from Conyers provides an overview of, among other things, the rights of a third party, the limitations on the third party, the variation and rescission of a contract, and defenses

The SEC Division of Investment Management issued guidance relating to the enhanced mutual fund disclosure amendments that were adopted in 2009. After finding that mutual fund prospectuses were too long and contained too much complex language, in 2009, the SEC amended Form N-1A , the registration form used by mutual funds, and Securities Act Rule 498 ("Summary Prospectuses for Open-End Management Investment Companies"). The amended Rule 498 provided a new option for satisfying prospectus delivery obligations with respect to mutual fund securities. According to the guidance, the amendments

FINRA issued a Regulatory Notice regarding Final Renewal Statements for broker-dealers and investment adviser firms and representatives, as well as reports that are now available on FINRA's Web CRD/IARD. The Final Renewal Statements include the following fees: Web CRD system processing fees; FINRA branch office processing fees; exchange maintenance fees; state broker-dealer firm, branch and agent renewal fees; state investment adviser firm, branch and investment adviser representative renewal fees; and FINRA annual statutory disqualification fees for registered individuals. FINRA noted that