The CFTC Division of Market Oversight ("DMO") granted time-limited relief to a master fund investment manager, a related holding company, and the four shareholders of the company from compliance with certain position aggregation requirements under CFTC Rule 150.4. The Division granted the relief even though transaction information firewalls were not maintained (as normally required for such an exemption), because the transaction information is being used only for currency hedging performance evaluation and risk management monitoring. DMO also cited the fact that the relief is limited to

Two initial coin offering ("ICO") issuers each agreed to pay $250,000 to settle SEC charges of offering and selling ICO tokens without (i) registering them pursuant to securities laws or (ii) qualifying for an exemption to registration requirements under the Securities and Exchange Act of 1934. The two settlement agreements ( see here and here) are the SEC Cyber Unit's first cryptocurrency-related cases imposing civil money penalties exclusively for selling ICO securities in violation of offering registration requirements and without allegations involving fraud. In addition to paying the civil

FINRA provided the filing dates for broker-dealer annual audit, FOCUS, and custody reports for 2019 and the first quarter of 2020.

FINRA proposed to amend FINRA Rule 4570, which requires a broker-dealer that withdraws from SEC registration to designate a person to act as custodian of the firm's books and records. Currently, the custodian must be an individual associated with the firm at the time the broker-dealer withdraws from registration. FINRA proposed to amend Rule 4570 to: give the withdrawing firm the option to designate another FINRA member broker-dealer ( e.g., an introducing firm's clearing broker) to act as custodian of its books and records after the firm withdraws from registration; and clarify the

The Federal Reserve Board ("FRB") approved final amendments to simplify the electronic collection of checks and funds. The final amendments make changes to Regulation J, which will (i) simplify provisions concerning electronic check collection, (ii) remove redundant or obsolete terminology and provisions, and (iii) accommodate recent changes to Regulation CC concerning electronic check collection and return provisions. The final amendments also amend Regulation J, Subpart B to "clarify that terms utilized in financial messaging standards do not signify legal status or responsibilities." The