In a blog post titled "Capital My Boy, Capital: Or, the Day of the MiFIDs," University of Houston finance professor Craig Pirrong discussed regulation of the capital structures of firms across the European Union. He suggested that the European Securities and Markets Authority's ("ESMA") regulation, which would likely subject the same type of capital requirements to firms that engage in financial intermediation as firms that serve as intermediaries in physical commodities, "is like the proverbial poor carpenter who owns only a hammer, so that everything looks like a nail." Professor Pirrong

Federal Reserve Governor Daniel Tarullo offered "starting points for shaping – or reshaping – applicable capital regulation" for non-bank actors including some large insurance firms and asset managers. At a Banque de France Conference held in Paris titled "Financial Regulation – Stability versus Uniformity; A Focus on Non-bank Actors" Governor Tarullo argued that current rules fail to make distinctions between traditional insurance firms and those that could pose greater risks to the broader economy. As to insurance companies, this is due, in part, to a state-by-state implementation of the

The CFTC issued an order adding the interest rate and foreign exchange asset classes to ICE Trade Vault, LLC ("ICE"), as a provisionally registered swap data repository, pursuant to CEA Section 21 ("Swap Data Repositories") and Part 49 of CFTC Regulations ("Swap Data Repositories"). In the order, the CFTC reminded ICE that it continues to be fully subject to all the provisions of the Provisional Registration Order as well as CFTC regulations and guidance.

The SEC's final rule removing references to credit ratings in Investment Company Act Rule 2a-7 ("Money Market Funds") and (ii) Form N-MFP ("Monthly Schedule of Portfolio Holdings of Money Market Funds") was published in the Federal Register. The adopted rule amends the issuer diversification provisions in Rule 2a-7 (the principal rule that governs money market funds) to eliminate an exclusion that is available currently for securities, subject to a guarantee issued by a "non-controlled" person. The amendments will implement Section 939A ("Removal of Statutory References to Credit Ratings") of

The SEC announced that it is seeking public comment on the effectiveness of financial disclosure requirements in Regulation S-X (which generally prescribes the requirements for financial reporting by SEC-registered issuers). The request for comment focuses on the requirements for the form and content of financial disclosures that companies must file with the SEC regarding acquired businesses, affiliated entities, and guarantors and issuers of guaranteed securities. The request for comment is part of the Disclosure Effectiveness Initiative, which is a broad-based SEC review of the disclosure