An SEC-proposed new rule and amendments that would "streamline and enhance" the regulatory framework for fund of funds was published in the Federal Register. Comments must be submitted by May 2, 2019. As previously covered, under the proposal, a fund would not need an individual exemption order from the SEC when it takes shares from another fund that exceed Investment Company Act limits.

The SEC extended, and granted on a permanent basis, certain exemptions from Exchange Act requirements related to security-based swap activity. The new Order extends relief initially granted in 2011 and most recently extended in 2018. The SEC also ordered, on a permanent basis, that: security-based swap transactions between eligible contract participants are exempt from the definition of "penny stock" set forth in Exchange Act Section 3(a)(51) and Rule 3a51-1; and security-based swaps are exempt from the definition of "municipal securities" in Exchange Act Section 3(a)(29). The SEC declined to

The Office of the Comptroller of the Currency ("OCC") revised the " Subsidiaries and Equity Investments" booklet of the Comptroller's Licensing Manual. The updated version describes the activities of federal savings associations that "may be performed in operating subsidiaries and service corporations, or through pass-through investments." The revised booklet: outlines the types of subsidiaries and other business entities that banks may "establish or acquire and the activities in which such entities may engage"; specifies permissible equity investments; outlines "permissible and incidental

ISDA recommended ways in which policymakers can reduce "fragmentation" in global derivatives markets. ISDA recommended, among other things, that regulators: minimize the gaps between globally agreed-upon standards and national requirements; institute global standards "when and where appropriate" for smaller jurisdictions or for those with "limited market activity," while permitting market participants from larger jurisdictions to engage in de minimis activity in these jurisdictions; and establish a risk-based framework "for the evaluation and recognition of the comparability of derivatives

The NFA adopted an Interpretive Notice (the "Notice") requiring commodity pool operator ("CPO") to implement an internal controls framework designed to protect customer funds and to ensure the books and records are accurate. The effective date is April 1, 2019. As previously covered, the Interpretive Notice requires that CPOs have: a robust control environment, including by implementing written policies to comply with applicable NFA and CFTC requirements; written internal control policies that should (i) explain the firm's internal controls, (ii) subject all personnel, including senior