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In a newly published User's Guide, the Alternative Reference Rates Committee ("ARRC") explained how market participants can use the Secured Overnight Financing Rate ("SOFR") in cash products. The ARRC called on market participants who are able to use SOFR to not wait for forward-looking SOFR term rates to begin their transition away from LIBOR. Seeking to encourage adoption of the overnight rate in cash products, the ARRC explained the differences between "simple" versus "compounded" average, "in advance" versus "in arrears" compounding, as well as some of the conventions that will need to be

An FDIC request for feedback on improving an agency rule that mandates certain insured depository institutions ("IDIs") to submit resolution plans (the "Plan Rule") was published in the Federal Register. Comments must be submitted by June 21, 2019. As previously covered, the Plan Rule requires an IDI with over $50 billion in total assets to submit a resolution plan that allows the FDIC to resolve the IDI in the event of its insolvency. Specifically, the FDIC seeks comments on certain approaches under consideration, including: the creation of "tiered resolution" planning requirements contingent

The SEC approved a proposal to amend FINRA Rule 4570. The rule requires a broker-dealer that withdraws from SEC registration to designate a person to act as custodian of the firm's books and records. The amendments will become effective on August 19, 2019. As previously covered, FINRA proposed to amend Rule 4570 to: give the withdrawing firm the option to designate another FINRA member broker-dealer ( e.g., an introducing firm's clearing broker) to act as custodian of its books and records after the firm withdraws from registration; and clarify the responsibilities of the books and records

The MSRB proposed to eliminate MSRB Rule G-29. The rule requires that an up-to-date copy of the MSRB rules be kept in each office where municipal securities dealer activities are performed. As part of its retrospective rule review, the MSRB stated that, "in light of the widespread availability of the MSRB Rulebook online," Rule G-29 is not necessary to ensure customers and municipal securities professionals have access to MSRB rules. In addition, the MSRB noted that the proposal contributes to continuing efforts to enhance market efficiency by removing unneeded regulatory requirements. The