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A private-sector working group on euro risk-free rates proposed guiding principles for fallback provisions in new contracts for euro-denominated cash products. The European Central Bank provided the secretariat for the working group. The working group highlighted the importance of market participants adequately preparing for a transition to risk-free rates. The new fallback language, according to the working group, should take into account the following principles: new fallback provisions should include a "permanent cessation trigger event"; "trigger events" should be objective; market

Commentary by Conor Almquist

The Enforcement Section of the Massachusetts Securities Division of the Office of the Secretary of the Commonwealth (the "Division") filed a Complaint against a broker-dealer and its agent for allegedly violating state securities laws. In particular, the Division alleged that Royal Alliance Associates, Inc. ("RAA") engaged in supervisory failures with regard to "unsuitable recommendations" made by a sales representative to a pair of senior Massachusetts residents (the "investors"). According to the Complaint, the representative allegedly breached his fiduciary duty by recommending an

SIFMA supported a Fixed-Income Clearing Corporation ("FICC") proposed rule change to expand the number of firms eligible to act as "Sponsoring Members" for repurchase transactions in U.S. government securities. In a comment letter to the SEC, SIFMA stated that FICC's proposed rule change would help to "improve overall resiliency" of the repurchase agreement market through better liquidity and risk management "provided by broader access to central clearing."

Commentary by Mark Highman

FINRA reminded broker-dealers that OTC transactions in TRACE-eligible securities are subject to TRACE reporting even if the security is listed on a national securities exchange. The exemption from TRACE reporting for listed bonds applies only where the transaction is executed on, and reported to, a national securities exchange and the transaction information is disseminated publicly; the exemption does not extend to OTC transactions in those bonds.

Bob Zwirb Commentary by Bob Zwirb

President Donald J. Trump signed the " Foundations for Evidence-Based Policymaking Act of 2018" (the "Act"). The new law is intended to improve the federal government's use of data to make policy decisions. The Act was introduced in the House by Representative Paul Ryan (R-WI) and co-sponsored by Representative Blake Farenthold (R-TX), Representative Trey Gowdy (R-SC) and Representative Derek Kilmer (D-WA). The Act was introduced in the Senate by Senator Patty Murray (D-WA). The Act was informed by recommendations from a report on how to improve the evidence available for making decisions