The MSRB announced that it is extending the due date for the first submissions of information about 529 college savings plans by 60 days. New MSRB Rule G-45 requires the underwriters of 529 college savings plans to provide the MSRB with information regarding their plans' assets, contributions, withdrawals, fees and cost structure. Underwriters must submit the required information to the MSRB by October 28, 2015. See: MSRB Press Release.

FERC issued a notice requesting comments on its proposed five-year review of the index level used to determine annual changes to oil pipeline rate ceilings. FERC proposed an index level between the Producer Price Index for Finished Goods ("PPI-FG") plus 2.0 percent and PPI-FG plus 2.4 percent for the five-year period commencing on July 1, 2016. FERC is requesting comments regarding its proposal and any alternative methodologies for calculating the index level.

ESMA issued to the European Commission the Final Report on MiFID II/MiFIR draft technical standards on authorization, passporting, the registration of third-country firms and cooperation between competent authorities. The European Commission has three months to adopt, reject or amend the standards. The remaining draft technical standards will be published by the end of 2015. See: Final Report.

SEC Commissioner Luis A. Aguilar discussed the role of chief compliance officers ("CCOs") in maintaining integrity in the securities industry. Commissioner Aguilar expressed concern that recent "public dialogue" has created an impression that the SEC is taking a harsh enforcement stance against CCOs and that they are "under siege from the SEC." Commissioner Aguilar emphasized that this impression is not only incorrect, but also can "discourage honest and competent CCOs from doing their work." Commissioner Aguilar stressed that CCOs who do their jobs "competently, diligently, and in good faith"

In Madden v. Midland Funding LLC, No. 14-2131-cv, ECF No. 75 (2d Cir. May 22, 2015) ("slip op."), pet. for reh'g filed, ECF No. 96-1 (2d Cir. June 19, 2015), the United States Court of Appeals for the Second Circuit held that the application of state usury laws to third-party assignees is not preempted by the National Bank Act. Instead, such assignees remain subject to state usury limits. Prior to Madden, market participants assumed that a fully funded loan that was valid and enforceable when made would remain valid and enforceable (with respect to the rate of interest accruing) regardless of