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The Office of the Comptroller of the Currency and other federal agencies issued a final rule and interpretations on threshold exemptions from special appraisal requirements for higher-priced mortgage loan transactions.

The North American Securities Administrators Association ("NASAA") will continue to waive fees for the Investment Adviser Registration Depository system for state-registered investment adviser firms. NASAA stated that the waiver will continue through 2019 (the waiver started on October 24, 2016). Separately, NASAA reported that enrollment fees for the NASAA Series 63, 65 and 66 exams, as well as the Electronic Filing Depository system fee for Form D Rule 506, will remain at last year's levels.

The public comment period for the final rule increasing the transparency of broker-dealers' "handling and routing of orders in NMS stock" will end on December 6, 2018. As previously covered, the effective date is January 18, 2019 and the compliance date is May 20, 2019.

Steven Lofchie Commentary by Steven Lofchie

U.S. House Representative Pramila Jayapal (D-WA) introduced companion legislation to Senator Elizabeth Warren's (D-MA) wide-ranging Senate "Anti-Corruption" bill ( see previous coverage). The purpose of the Act is to eliminate the "dominance of money in federal decisions." The Anti-Corruption and Public Integrity Act would, among other things: require the majority of executive branch employees to recuse themselves from all matters that might provide financial benefits personally, or to a previous employer or client from the prior four years; bar current lobbyists from taking government jobs

The CFTC final rule amending the uncleared swap margin requirements was published in the Federal Register. The final rule will become effective on December 26, 2018. As previously covered, the amendments were adopted to comply with the stay-related rules applicable to "qualified financial contracts" ("QFCs"). Further, the adopted amendments clarify that (i) swap agreements are notexcluded from the CFTC Margin Rule definition of "eligible master netting agreement," based on their compliance with the QFC rules, and (ii) any legacy uncleared swap that is out of scope for the CFTC swap margin