On January 20, 2015, the Chicago Board Options Exchange ("CBOE") submitted a comment letter to the IRS on proposed regulations issued under Section 871(m) of the Internal Revenue Code ("Code") relating to the imposition of a withholding tax on certain dividend-equivalent payments. In its comment letter, the CBOE argued in favor of an exemption from 871(m) withholding for broad-based indexes and certain "narrow-based indexes," as defined under both the Securities Exchange Act of 1934 and Section 1256 of the Code. The CBOE also emphasized that the currently proposed 70 delta test for imposing

Office of the Comptroller of the Currency ("OCC") Deputy Comptroller for Supervision Risk Management Darrin Benhart delivered remarks at the Global Association of Risk Professionals conference. His remarks concerned emerging risks in the financial services industry and the OCC's efforts to identify and respond to the new risks that must be faced by national banks and federal savings associations. See: Mr. Benhart's Remarks.

The MSRB published its annual Fact Book, an online sourcebook that analyzes trading data, continuing disclosure documents and other statistics from the municipal bond market. The new edition provides monthly, quarterly and yearly aggregate market information from 2010 to 2014, and covers different types of municipal issues, trades and interest rate resets. Highlights from the Fact Book include the following: a decrease of 16 percent in the number of municipal securities trades in 2014 as compared to the previous year, while submissions of continuing disclosures increased by nearly 19 percent

The CFTC reopened the comment periods for the Position Limits for Derivatives and the Aggregation of Positions proposals. The reopened comment periods and their deadlines were published in the Federal Register. The CFTC reopened the comment periods in order to provide commenters with (i) a sufficient period of time to respond to questions raised and points made at the CFTC Energy and Environmental Markets Committee meeting scheduled for February 26, 2015, and (ii) the opportunity to comment on the new provisions in Table 11a of the position limits proposal. Comments on both proposals are due

The Federal Deposit Insurance Corporation ("FDIC") issued a request for comments on a new draft of its long-range strategic plan. The draft is titled "FDIC Strategic Plan, 2015-2019." The major areas of focus in the FDIC's strategic plan mirror those of its mission statement: insuring deposits, examining and supervising financial institutions for safety, soundness and consumer protection, making large and complex financial institutions resolvable, and managing receiverships. Comments are due by March 10, 2015. See: FDIC Press Release.