The CFTC Division of Swap Dealer and Intermediary Oversight issued an extension of previously issued time-limited, no-action relief to the Futures Industry Association, its member futures commission merchants ("FCMs"), and similarly situated FCMs regarding the simultaneous recording of book entry credits upon the receipt of customer funds via a wire transfer by an FCM. The relief extends previously issued no-action relief in Letter 14-88 pertaining to CFTC Rules 1.20 ("Futures Customer Funds to be Segregated and Separately Accounted For"), 22.2 ("Futures Commission Merchants: Treatment of

The CFTC Division of Swap Dealer and Intermediary Oversight issued an interpretation providing guidance as to the applicability of certain provisions of Commission Rules 23.701 ("Notification of Right to Segregation") and 23.704 ("Requirements for Non-Segregated Margin"). These regulations impose certain notification and reporting requirements on swap dealers ("SDs") and major swap participants ("MSPs") with involving margin posted by counterparties in uncleared swap transactions. Responding to several inquiries regarding the applicability of the regulations, the interpretation clarifies to

Academic researchers from the University of Colorado and University of Chicago published a paper titled " Run EDGAR Run: SEC Dissemination in a High-Frequency World," which finds that the delay between an SEC filing's acceptance by the Electronic Data Gathering, Analysis, and Retrieval System ("EDGAR") and its initial public availability on the SEC website, may provide an advantage to certain traders that pay a subscription fee for direct access. According to the paper, while the delay is "relatively short," with a median posting time of 36 seconds, prices, volumes, and spreads respond to the

At SIFMA's Listed Options Symposium, the organization's Executive Vice President Randy Snook spoke about the importance of listed options and the challenges that market structure imposes on these financial products. Mr. Snook explained that "SIFMA has long called for a holistic and comprehensive review of market structure" and that options should be part of the review. He noted that certain ideas are working well in the listed options market and could be applied to other markets. He voiced support for the Office of the Comptroller of the Currency's initiative to adopt the principles-based risk

At a meeting in Berlin on October 29, 2014, 51 countries and jurisdictions signed a multilateral competent authority agreement to implement the Organisation for Economic Co-operation and Development's ("OECD's") new automatic exchange of tax information standard, which is referred to as the Common Reporting Standard ("CRS"). The agreement, which is based on the Model 1 Intergovernmental Agreement developed by the United States under FATCA, allows countries to adopt enhanced due diligence and reporting requirements on their financial institutions in order to collect information and to