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Commentary by Nihal Patel

The CFTC voted unanimously to propose a rule that would apply the CFTC's margin requirements for uncleared swaps in the context of cross-border transactions. On June 29, 2015, the CFTC voted to publish proposed rules regarding the cross-border application of its margin requirements for uncleared swaps (the " CFTC Cross-Border Proposal" or " Proposal"). The CFTC Cross-Border Proposal follows the CFTC's proposal for margin requirements for uncleared swaps (" Margin Proposal"), [1] which was published in October 2014 and included an advance notice for proposed rulemaking as to the cross-border

The SEC Division of Investment Management issued an Investment Management Guidance Update regarding personal securities transactions reports. The update is directed toward registered investment advisers reports on securities held in accounts over which reporting persons had no influence or control. According to the Guidance Update, Investment Advisers Rule 204A-1 ("Investment Advisor Code of Ethics") provides that a registered investment adviser must establish, maintain, and enforce a written code of ethics that require, among other things, its directors, officers and partners and its

SEC Commissioner Luis A. Aguilar discussed ways in which the SEC approaches cybersecurity and areas where there is room for improvement. He delivered his remarks at the SINET Innovation Summit. Commissioner Aguilar stressed that cyber attacks are becoming more pervasive, dynamic, and clandestine year-after-year. He urged the SEC to "sharpen its own focus on the cybersecurity threat, by forming an internal working group" that aims to combine the SEC's resources to address cybersecurity issues. He also suggested that the private and public sectors form a "vibrant partnership" to build an

NFA filed with the CFTC proposed amendments to NFA's Articles of Incorporation regarding the Board of Director's structure and composition. Generally, the NFA Board is made up of representatives of these distinct classes: (i) contract markets; (ii) FCMs, LTMs and IBs; (iii) CPOs and CTAs; (iv) swap dealers; and (v) public representatives. The amendments would reduce the number of representatives from every class, with the FCMs, LTMs and IBs and the swap dealers each losing two representatives, and the other groups each losing one representative. NFA stated that pending the CFTC's approval, it

The Government Accountability Office ("GAO") issued a report titled "Lessons Learned and a Framework for Monitoring Emerging Risks and Regulatory Response." The report outlines a framework the GAO will use to monitor regulators' efforts to identify and respond to emerging risks to the banking system. The GAO reviewed its prior studies and those of federal banking regulators, the regulators' inspectors general, and academics that evaluated regulators' efforts to identify and respond to risks that led to bank failures in past crises. In its review, the GAO determined that there are a number of