In comments submitted to the U.S. Senate Banking Committee, SIFMA and the Managed Funds Association ("MFA") offered feedback on data privacy, protection and collection. SIFMA advised Congress to: ensure that any privacy regime is flexible enough to allow the use of new technology and foster innovation; devise a federal data breach notification regime that preempts state laws and existing federal regulations and guidance; be aware of the need to "harmonize any future privacy obligations," which may include new consumer rights, with current legal obligations for financial institutions; and

U.S. prudential regulators, including the Federal Reserve Board, Office of the Comptroller of the Currency, FDIC, Farm Credit Administration and the Federal Housing Finance Agency issued an interim final rule to create certain Brexit-related swap margin requirement exceptions. The interim final rule was published in the Federal Register (see here for previous coverage). The interim final rule is effective on March 19, 2019. Comments must be submitted to the regulators by April 18, 2019.

The Public Company Accounting Oversight Board ("PCAOB") issued guidance to support the implementation of new critical audit matter ("CAM") requirements. The PCAOB staff guidance includes three documents: (i) " Implementation of Critical Audit Matters - The Basics," (ii) " Staff Observations from Review of Audit Methodologies" and (iii) Implementation of Critical Audit Matters - Deeper Dive on Determination of CAMs. PCAOB stated that "these documents primarily offer insights for auditors, [however] the high-level overview — “The Basics” — may also be of interest to preparers, audit committees

The CFTC Division of Swap Dealer and Intermediary Oversight granted no-action relief to two CPOs from registration, provided that each delegates its responsibilities under CEA Section 4m(1) to a registered CPO, subject to certain conditions. (See here and here for the no-action letters.)

Market participants and industry associations raised a number of concerns on the CFTC proposals to amend swaps trading rules.