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In the latest issue of The Risk Desk, CFTC Commissioners Dan Berkovitz and Rostin Behnam shared their perspectives on a number of recent proposals, including amending the rules governing swap execution facilities ("SEFs") and the registration threshold for swap dealers. Mr. Berkovitz, who was sworn in as a Commissioner last month, and who had served as the agency's General Counsel in the previous administration, stated that the Commission should more closely examine SEFs. Conceding that the "trading mandate has not worked totally as the vision," Mr. Berkovitz questioned whether the lack of

Federal banking regulators testified before the U.S. Senate Committee on Banking, Housing and Urban Affairs on progress toward implementing the Economic Growth, Regulatory Relief and Consumer Protection Act (the "Act"). As previously covered, the Act makes targeted changes to key areas of Dodd-Frank, which will primarily benefit smaller banking organizations with simpler business models. Testimony was provided by Comptroller of the Currency Joseph M. Otting; Federal Reserve Board ("FRB") Vice Chair for Supervision Randal K. Quarles; FDIC Chair Jelena McWilliams; and National Credit Union

The National Futures Association ("NFA") provided guidance to commodity pool operators ("CPOs") and commodity trading advisors ("CTAs") on avoiding financial ratio errors on NFA Forms PQR and PR. In an Interpretive Notice, the NFA reported that some members have been incorrectly calculating two financial ratios regarding the financial condition of CPOs or CTAs - the Current Asset/Current Liability ratio and the Total Revenue/Total Expenses ("TR/TE") ratio. The NFA advised CPOs and CTAs to remember that: ratios must be calculated using the accrual method of accounting; current asset balance

The FDIC, the Federal Reserve Board and the Office of the Comptroller of the Currency ("OCC"), with the help of the Federal Financial Institutions Examination Council ("FFIEC"), proposed revisions to the Consolidated Reports of Condition and Income ("Call Report") and other FFIEC reports. The proposed revisions are in response to changes in accounting for credit losses under the Financial Accounting Standards Board's Accounting Standards Update. The proposed revisions - arising from the Economic Growth, Regulatory Relief and Consumer Protection Act - relate to the reporting of high-volatility