The CFTC Division of Swap Dealer and Intermediary Oversight issued a letter providing no-action relief to entities operating issuers of insurance-linked securities ("ILS Issuer") subject to specific conditions. The operator of an ILS Issuer that meets the conditions outlined in the letter may claim an exemption from CPO registration consistent with CFTC Rule 4.13(a)(3) ("Exemption From Registration as a Commodity Pool Operator"), with respect to the issuance of insurance-linked securities. In addition to meeting the operational and substantive conditions of relief, an operator of an ILS Issuer

The Cayman Islands Tax Information Authority ("TIA") issued a revised version of the Cayman Islands FATCA Guidance Notes ("Revised Guidance Notes") on December 15, 2014. The Revised Guidance Notes replaces the previous version issued on July 22, 2014. Additional guidance includes the following: An Investment Advisor or Manager may still be a Nonreporting Foreign Financial Institution even if it also acts as General Partner of an Investment Fund; and Providing certain "administrative services" to another entity, such as provision of a registered office, preparation of tax returns or financial

SEC Commissioner Luis Aguilar answered questions about updating the rules that regulate transfer agents. It is time, he said, for the SEC to close the gap that has developed between transfer agent rules and their actual activities in the current business environment. According to Commissioner Aguilar, transfer agents play an important role in capital markets, since they act as registrars and keep track of changes in the record of ownership of a company's securities. He explained that because transfer agent rules under Section 17A of the Exchange Act were originally adopted in 1977

The Financial Stability Oversight Council ("FSOC") voted to designate MetLife, Inc. as a non-bank systemically important financial institution. In response to the designation, MetLife issued a statement expressing disappointment with FSOC's decision, explaining that it believes "MetLife is not systemically important under the Dodd-Frank Act's criteria, and the company has presented substantial and compelling evidence to FSOC to support this conclusion." Se e: FSOC Readout from December 18, 2014 Meeting; FSOC MetLife Designation. See also: FSOC Proposes Preliminary Designation of MetLife as a

The Financial Stability Oversight Council ("FSOC") issued a notice seeking input from the public on the potential risks associated with liquidity and redemptions, leverage, operational functions, and resolution in the asset management industry. Comments from the public must be received no later than 60 days after the notice is published in the Federal Register. Lofchie Comment: Having been criticized for the suggestion that investment advisers might be regulated as systemically significant organizations, FSOC now is more focused on funds than advisers. This seems a logical area in which to