The SEC Division of Corporation Finance (the "Division") agreed that Transferable Custody Receipts (described in the no-action letter as the Australian equivalent of American Depository Receipts) could be sold in Australia to U.S. market makers without registration under the Securities Act. The Division's decision was made on the basis that the transactions taking place outside the United States were generally in accordance with Regulation S.

The Federal Reserve Board ("FRB") rule adopting a new supervisory rating system for large financial institutions was published in the Federal Register. The final rule is effective starting on February 1, 2019. As previously covered, the FRB will enforce a new rating system for large financial institutions ("LFI"). The new LFI rating system will apply to (i) all domestic bank holding companies and non-insurance, non-commercial savings and loan holding companies ("SLHCs") with $100 billion or more in total consolidated assets and (ii) U.S. intermediate holding companies of foreign banking

In recently submitted comments, SIFMA, ISDA, the FIA, Morgan Stanley and Citadel, among others, urged the SEC to substantially revise proposed rules on capital, margin and segregation requirements for security-based swap dealers ("SBSDs"). The proposal (summarized here) would set minimum capital and margin requirements for non-bank SBSDs and collateral segregation requirements for all SBSDs. In its comment letter, SIFMA made a number of significant recommendations as to how the SEC should the rulemaking and called for either an extension of the comment period or formally re-proposing the rules

The Financial Stability Board ("FSB") provided an update on FSB member progress on (i) G20 reforms for the over-the-counter ("OTC") derivatives markets and (ii) legal barriers to reporting and accessing trade data sets that were identified in a 2015 peer review. With respect to the G20's OTC reform agenda, the FSB found that: 21 out of 24 FSB member jurisdictions have trade reporting requirements fully implemented (up by two since June 2017); 18 member jurisdictions have standards for requiring clearing of standardized OTC derivatives; 16 jurisdictions have adopted margin requirements for non

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