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Commentary by Nihal Patel

CFTC Commissioner J. Christopher Giancarlo released a white paper titled "Pro-Reform Reconsideration of the CFTC Swaps Trading Rules: Return to Dodd-Frank" (the "White Paper"), which proposes an alternative to the CFTC's swaps trading framework. The White Paper is critical of the implementation of the swaps trading framework, asserting that there is a "fundamental mismatch" between the CFTC's framework and the "distinct liquidity and trading dynamics of the global swaps market." According to the White Paper, the CFTC framework is "highly over-engineered, disproportionately modeled on the U.S

The MSRB published a Market Advisory calling for greater transparency of the debt obligations of municipal bond issuers. The MSRB had initially called on local and state governments to make information about their bank loans publicly available on a voluntary basis in 2011 and again in 2012. The MSRB stated that it is concerned that the increasing use of bank loans and direct-purchase debt as financing alternatives to public offerings in the municipal securities market for funding capital improvement projects or refunding outstanding bonds could "impair the rights of existing bondholders, or

The SEC issued a request for comment regarding the proposed collection of information under Investment Company Act Rule 23c-1(a). The Rule applies when a closed-end registered investment company repurchases its securities for cash. The SEC is requesting comments on the following subjects: whether the collection of information is necessary for the proper performance of the functions of the SEC, including whether the information has any practical utility; the accuracy of the SEC's estimate of the burden of the collection of information (1755 hours annually); ways to enhance the quality, utility