University of Houston finance professor Craig Pirrong discussed the "CFTC's frustration at the failure of SEFs to get traction" in his blog post titled "SEFs: The Damn Dogs Won't Eat It!" According to Professor Pirrong, Swap Execution Facilities (SEFs) are the "solution in search of a non-existent problem."Professor Pirrong explained that, in crafting SEFs, regulators took a narrow, one-size-fits-all approach by assuming that centralized order-driven markets were the best way to execute all transactions. In doing so, Professor Pirrong stated, regulators focused on pre-trade and post-trade

The IRS recently released an internal legal memorandum ( CCA 201436049), which concluded that partners in a limited liability company, taxed as a partnership that provides investment management services to a family of investment partnerships, are required to pay self-employment taxes on their distributive share of the partnership's income. The Management Company treated all of its partners as limited partners and only treated the guaranteed payments made to such partners as subject to self-employment tax. The Management Company succeeded an S corporation that provided similar services to the

The House Financial Services Committee held a hearing titled "An Overview of the Credit Reporting System." The hearing discussed the roles and responsibilities of the consumer reporting agencies, as well as the users and furnishers of consumer credit data. The following witnesses testified: Mr. Stuart Pratt, President and Chief Executive Officer, Consumer Data Industry Association; Mr. J. Howard Beales, Professor of Strategic Management and Public Policy, George Washington University; Mr. John A. Ikard, President and Chief Executive Officer, FirstBank Holding Company, on behalf of the American

The SEC announced accounting and disclosure fraud charges against a bank holding company for failing to report the true volume of loans that were at least 90 days past due, which increased substantially in number during the financial crisis. An SEC investigation found that, as the real estate market declined in 2009 and 2010 and its construction loans began to mature without repayment or completion of the underlying project, the bank did not renew, extend or take other appropriate action for 90 days or more on a material amount of its matured loans. According to the SEC Order, instead of fully

The North American Securities Administrators Association ("NASAA") announced that it convened a working group consisting of state securities regulators and representatives of FINRA, SIFMA and the Financial Services Institute to develop improved broker-dealer fee disclosure. According to NASAA President Andrea Seidt, the working group will consider different types of firms, including wirehouse firms, independent broker-dealers, clearing firms and introducing firms. It will also consider a variety of options, including a model fee disclosure form, accessibility and transparency guidelines