The CFTC will revise application Form 7-R, for registration as an entity engaged in specified business in the derivatives market. Form 7-R is generally used by CFTC registrants that also are required to become NFA members. Firms that must file Form 7-R include CPOs, CTAs, introducing brokers, floor traders, retail foreign exchange dealers, FCMs, leverage transaction merchants and swap dealers. Form 7-R will be amended to include: new "functionality," which consists of hyperlinks to the text of the relevant provisions of the law; certain "clarifying" language where appropriate ( e.g., the word

The Federal Reserve Board ("FRB") request for feedback on amending Regulation D ("Reserve Requirements of Depository Institutions") was published in the Federal Register ( see here for previous coverage). Comments must be submitted to the FRB by May 13, 2019.

In its March 8, 2019 Financial Institution Letter, the Federal Financial Institutions Examination Council ("FFIEC") finalized revisions to the Consolidated Reports of Condition and Income ("Call Report"), as well as to certain other reports, in accordance with changes in the accounting for credit losses pursuant to the Financial Accounting Standards Board's Accounting Standards Update 2016-13. Highlights of the revisions include changes to the Call Report and the FFIEC 101 report to implement the banking agencies' recent revisions to the regulatory capital rules and reporting changes. These

ISDA CEO Scott O'Malia commended the Basel Committee on Banking Supervision and IOSCO ("BCBS-IOSCO") statement on the implementation of derivatives margin requirements and urged additional action. As previously covered, the BCBS-IOSCO statement addressed the implementation of derivatives margin requirements as they relate to (i) benchmark reforms and (ii) initial margin thresholds. Mr. O'Malia commended the BCBS-IOSCO statement for addressing the potential application of documentation and other requirements where parties fall below the EUR 50 million threshold in the BCBS-IOSCO margin

The Financial Information Forum ("FIF") offered recommendations to streamline the Regulation ATS-N submission process. The process requires broker-dealers to publicly post Form ATS-N filings on the SEC's website. In a comment letter to the SEC, FIF recommended: permitting alternative trading systems ("ATSs") to submit disclosure information in formats other than narrative form when applicable ( e.g., in tables, charts and bullets); allowing ATSs to "cut and paste from internal documents," which would mitigate possible transcription mistakes; incorporating a "comment" field in Form ATS-N to