The SEC approved an amendment to FINRA’s Trade Reporting and Compliance Engine (TRACE) rules. The change will require certain alternative trading systems ("ATSs") to report to FINRA and the U.S. Treasury Department ("Treasury") (but not to the public) the identities of non-FINRA member subscribers that are parties to Treasury securities transactions. The new reporting requirement comes into effect on April 1, 2019. As previously covered, the reporting requirement would apply only to ATSs that have executed Treasury securities transactions with non-FINRA members in an amount equal to at least

The Global Foreign Exchange Committee ("GFXC") launched a survey to measure the awareness and adherence to the FX Global Code (the "Code"). The survey is intended to help the GFXC in determining effective mechanisms for encouraging compliance with the Code. The GFXC will consider the survey results at its next meeting, which will take place from November 29 to November 30, 2018. In addition, the GFXC provided updates on current initiatives: The "Cover and Deal" trading activity working group is drafting a summary highlighting how the Code may apply its good practice recommendations in the

The SEC proposed to codify an existing exemption available to rating agencies with respect to their obligations under conflicts of interest. The proposal was published in the Federal Register. Comments must be received by November 5, 2018. As previously covered, the exemptions under Exchange Act Rule 17g-5(a)(3) would be available only if (i) the issuer of the relevant security is not a U.S. person and (ii) the rating agency reasonably believes that all offers and sales of the instrument will occur outside the United States, in each case as such terms are defined in Regulation S under the

The SEC Division of Corporation Finance updated guidance to the issuers of asset-backed securities ("ABS") on procedures for filings on the EDGAR system. As previously covered, the guidance was originally issued to reflect revisions to Regulation AB and Exchange Act Rule 15Ga-2. The updated guidance clarifies that an issuer is not required to obtain Central Index Key Codes (CIK) for an issuing entity when furnishing the Form ABS-15G in connection with unregistered securities offerings. The guidance covers the procedures that a filer ( e.g., an ABS depositor) must use in the EDGAR system to

The CFTC Technology Advisory Committee ("TAC") public meeting was held on October 5, 2018. There were four panels at the meeting: a virtual currencies subcommittee presentation and digital asset security discussion; an automated and modern trading markets subcommittee presentation; a RegTech and robo-rulebook discussion; and a distributed ledger technology and market infrastructure subcommittee presentation.