SIFMA told the IRS and the U.S. Treasury Department that it is "commercially unreasonable" to implement the early effective date of final and temporary regulations promulgated under Internal Revenue Code Section 871(m) ("Tax on Nonresident Alien Individuals") for other types of financial instruments. In a comment letter, SIFMA urged regulators to defer the effective date to January 1, 2017 for all such instruments except (i) over-the-counter ("OTC") delta-one financial instruments with respect to U.S. corporations that are not held through financial intermediaries ("OTC delta-one instruments")

SEC Division of Enforcement Director Andrew Ceresney offered perspective on enforcement actions against compliance personnel. In an address to the National Society of Compliance Professionals, he focused on recent actions in the investment adviser space and clarified the circumstances under which the SEC takes action. He also discussed efforts to protect compliance officers. Mr. Ceresney argued that two recent enforcement actions demonstrate the SEC's efforts to protect the compliance function and its resource needs. In one of the actions, the SEC effectively charged the CEO with failing to

Listening to the various speakers at the sixth annual Swap Execution Facility Conference ("SEFCON VI"), Energy Metro Desk Editor in Chief John Sodergreen concluded that "there is no 'fix' on the horizon" for the uncertain status of swap execution facilities. Mr. Sodergreen asserted that the regulatory framework for swap trading designed by the CFTC "got it wrong, very wrong." Mr. Sodergreen opined on several issues raised at the conference, including: the value of the Dodd-Frank Act to the financial trading markets; the CFTC's use of the no-action process to regulate the swaps markets; cross

The Board of Governors of the Federal Reserve System ("FRB") requested comments on a proposed rule to "promote financial stability by improving the resolvability and resiliency of large, interconnected U.S. bank holding companies and the U.S. operations of large, interconnected foreign banking organizations" pursuant to Dodd-Frank Act Section 165 ("Enhanced Supervision and Prudential Standards for Nonbank Financial Companies Supervised by the Board of Governors and Certain Bank Holding Companies"). Specifically, the proposed rule would require: a U.S. top-tier bank holding company identified

The CFTC Division of Market Oversight ("DMO") extended no-action relief, which was granted in CFTC Letter 14-118, to swap execution facilities ("SEFs") from the "occurs-away" requirement under CFTC Rule 43.2 ("Definitions"). Relief was granted in order to (i) give DMO staff sufficient time to continue to review and evaluate SEF trading practices and functionalities for pre-execution credit checks; and (ii) allow the DMO to consider, develop and evaluate best practices and permanent solutions to the issues involved in screening block trade orders for compliance with risk-based limits, including