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The CFTC voted to establish the Interest Rate Benchmark Reform Subcommittee ("Subcommittee"). The Subcommittee will provide recommendations to the CFTC's Market Risk Advisory Committee about (i) ongoing efforts to transition U.S. dollar derivatives and related contracts to the secured overnight financing as an alternative to LIBOR and (ii) the impact that such a transition will have on liquidity in the derivatives markets. Nominations for membership to the Subcommittee must be submitted by October 16, 2018.

In a comment letter submitted to the Financial Stability Board ("FSB"), ISDA and the Global Financial Markets Association ("GFMA") responded to a recently published FSB report, Thematic Peer Review on Implementation of the Legal Entity Identifier. ISDA and GFMA described implementation issues related to the use of legal entity identifiers.

Beginning on October 1, 2018, financial service companies holding check casher and virtual currency business activity licenses may transition those licenses to the Nationwide Multistate Licensing System and Registry ("NMLS"). The New York Department of Financial Services stated that entities applying for new licenses will be able to apply through NMLS. NMLS, a web-based licensing system, allows entities to apply for, update, and renew their state licenses online.