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The NFA permanently barred a financial firm, previously an NFA Member introducing broker, from NFA membership. The decision is based on a complaint authorized by the NFA's Business Conduct Committee that alleged, among other things, that the firm failed to keep accurate financial records, failed to maintain the required minimum adjusted net capital, and willfully provided NFA with false and misleading information. See: NFA Press Release; NFA Business Conduct Committee Complaint. Related news: Investment Management Firm Settles Charge That It Failed to Disclose Conflict to Clients (August 10

ISDA's latest annual Margin Survey showed "a small decline in the total amount of collateral supporting non-cleared derivatives transactions in 2014, in part due to a continued shift to central clearing." ISDA stated that this shift has resulted in: (i) a significant increase of collateral supporting cleared transactions and (ii) a sharp growth in the number of client cleared collateral agreements, "as an increasing number of end users began clearing in response to regulatory changes." ISDA stated that its annual Margin Survey provides information about the use of collateral in the over-the

Bob Zwirb Commentary by Bob Zwirb

In an article titled "Considering the Cumulative Effects of Regulation," Director of the Regulatory Studies Center and Professor at George Washington University, Susan E. Dudley suggests that requiring agencies to analyze the expected impact of new regulatory requirements, while important, "may not account for the cumulative effect of regulations on society or specific sectors of the economy." Dudley argues that even if "individually justified," new regulatory requirements "may have cumulative effects imposing undue, unduly complex, or inconsistent burdens." The article addressed how the

The Managed Funds Association ("MFA") expressed concern that the SEC's proposed amendments to Form ADV would require "certain sensitive business information about client accounts that would not be appropriate for reporting and public disclosure." The MFA complained that the proposed information relating to gross notional amounts of derivatives in client accounts would provide an inaccurate representation of market exposures and would not provide information that is meaningful to the SEC. The MFA also stated, among other things, that other separately managed account ("SMA") clients' information

In a letter to the Department of Labor, Democratic members of the Senate Finance Committee made numerous recommendations regarding the re-proposed regulations defining who is a fiduciary of an employee benefit plan or individual retirement plan under ERISA." The Senators recommended that the DOL: (i) clarify the "best interest contract ("BIC") exemption" by utilizing a more workable contract requirement and include listed options in the definition of assets; (ii) expand the capability of financial professionals to provide specific investment education on retirement plans; (iii) continue to