The SEC charged Water Island Capital LLC, an investment adviser to several alternative mutual funds, with maintaining the funds' cash collateral at broker-dealer counterparties instead of at the funds' custodial bank. During an SEC examination of Water Island Capital LLC, the SEC uncovered the firm's failure to ensure that roughly $247 million in cash collateral held by broker-dealer counterparties was maintained with the funds' custodial bank. The cash collateral, which Water Island caused to be posted, related to the funds' investments in certain total return and portfolio return swaps

The North American Securities Administrators Association ("NASAA") filed a comment letter to update the SEC on the implementation and progress of NASAA's Coordinated Review Program for Regulation A Offerings. According to the comment letter, the Coordinated Review Program, which "streamlines state registration of offerings" under the Securities Act, has been successfully implemented. NASAA stated that, in every instance, the program "effectively streamlines the state review process and promotes efficiency by providing centralized filing, unified comments, and a definitive timeline for review."

CFTC Commissioner Chris Giancarlo discusses his white paper, the recent drops in oil prices and his priorities for the CFTC in the latest installment of Energy Metro Desk. Commissioner Giancarlo stated that he is "pleasantly surprised" at the reactions to his white paper, titled "Pro-Reform Reconsiderations of the CFTC Swaps Trading Rules: Return to Dodd-Frank," which he said was "meant to stir things up." The white paper provides an overview of issues regarding the current swaps policy and proposes an alternative framework. The article notes that Commissioner Giancarlo also "stirred things up

FINRA filed a proposed rule change with the SEC to adopt NASD Rules 3170, 1150 and 1160 as new FINRA Rule 4517 ("Member Filing and Contact Information Requirements") without any substantive changes. FINRA also proposed to update references and cross-references within other FINRA rules accordingly. See: Text of Proposed Rule Change.

The SEC announced that Pamela C. Dyson was appointed SEC's Chief Information Officer ("CIO") in charge of overseeing the SEC's information technology functions. Ms. Dyson served as the SEC's acting CIO since October 2014. Se e: SEC Press Release.