SIFMA recommended modifications to MSRB proposed rules on duties of non-solicitor municipal advisors. In a comment letter, SIFMA contended that the proposed Rule G-42 has "outstanding issues that need to be amended or clarified" before approval by the SEC. Among SIFMA's criticisms were the following: (i) the proposed transaction ban in Proposed Rule G-42(e)(ii) is more restrictive and inflexible than fiduciary obligations under any other financial regulatory regime; (ii) the MSRB crafted a "one-size-fits-all" rule by applying the same standards and obligations to all "municipal advisory

SIFMA and the Institute of International Bankers ("IIB") asserted that the CFTC's proposal for the cross-border application of its margin requirements for uncleared swaps (the "proposal") would "undermine" the Basel Committee on Banking Supervision / IOSCO Framework for margin requirements. In a comment letter, SIFMA and the IIB criticized the CFTC's approach to "substituted compliance," and argued that the limited availability of substituted compliance in the proposal (i) is not necessary to mitigate risk to the United States and (ii) "would result in overlapping rules that deter cross-border

The European Supervisory Authorities ("ESAs") overseeing securities ("ESMA"), banking ("EBA") and insurance and occupational pensions ("EIOPA"), published a joint report on cross-sectorial vulnerabilities and developments in the EU financial system. The ESAs' report determined that the following conditions have "persisted since March 2015": a low-interest-rate environment and its impact on the profitability and business model sustainability of financial institutions; the continued search for yield by financial institutions and the associated mispricing of assets; political and economic risks

SIFMA filed an amicus curiae brief with the Second Circuit Court of Appeals urging affirmation of a Southern District of New York decision dismissing the FDIC's Securities Act claims that were brought in reliance on the argument that the "FDIC Extender Statute," 12 U.S.C. § 1821(d)(14), should apply to the statutes of repose in Section 13 of the Securities Act. The SIFMA brief argues that the FDIC Extender Statute does not apply to the Securities Act claims because the FDIC Extender Statute is limited to "statutes of limitation" in state common law contract and tort claims and not applied to

New SRO rules, rule proposals and NMS plans were announced by the SEC. Click on the links below to view the SEC's notices of exchange rule changes and proposals from September 8 to September 11. Clearance Settlement: ICC: Notice of Filing of Amendments No. 1 and 2 and Order Granting Accelerated Approval of Proposed Rule Change, as Modified by Amendments No. 1 and 2, to Revise the ICC Risk Management Framework (Release No. 34-75887; File No. SR-ICC-2015-009; September 10, 2015) Fees, Fines, Rebates Claims: FINRA: Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to