SIFMA submitted comments regarding Federal Housing Finance Agency ("FHFA") guarantee fees ("g-fees") for Fannie Mae and Freddie Mac. SIFMA stated that efforts to reshape mortgage finance markets should carefully consider the costs, benefits, and likelihoods of success. Specifically, SIFMA explained that the question of appropriate g-fee levels should not be looked at in isolation, especially if g-fees are intended to be used as a policy lever to cause shifts in market dynamics outside of the government sponsored enterprises. Changes in g-fees, according to SIFMA, may cause originators to

SIFMA and the Mortgage Bankers Association ("MBA") submitted a joint comment letter to the Government National Mortgage Association ("GNMA") in response to its June 9, 2014 letter requesting feedback regarding the proposed combination of the Ginnie Mae I and II programs. In the letter, SIFMA identified specific issues that it is considering regarding combining the two Ginnie Mae programs and improving market execution, which include, among other things: considerations related to the wind-down of the Ginnie Mae I program and whether or not a conversion process is needed to allow Ginnie Mae I

The SEC announced charges against Crucible Capital Group and its founder for attempting to violate net capital requirements and falsify books and records to conceal the capital deficiencies. According to the SEC order, Crucible Capital and its founder attempted to disguise the firm's extensive and repeated net capital insufficiencies by improperly off-loading its liabilities onto the books of an affiliated firm and improperly treating non-marketable stock as an allowable asset. Additionally, the SEC found that the firm's founder provided doctored invoices to the SEC that sought to mask the

Seton Hall University School of Law professor, Stephen J. Lubben, published a paper titled "Nationalize Clearinghouses!" which argues for the nationalization of clearinghouses ("CCPs") upon any failure. In his paper, Professor Lubben argues: (i) bailouts of clearing houses are inevitable, because Dodd-Frank makes their failure too disruptive to be politically tolerated; (ii) the U.S. needs to enact clear, ex ante procedures to deal with the failure of a clearinghouse and address the consequences of a bailout; and (iii) those consequences must include clearly delineated outcomes for the

On Wednesday, August 6, 2014, Canada announced that it had expanded its Ukraine-related sanctions, subjecting a number of Russian and Ukrainian individuals and entities either to travel bans and asset freezes, or to more limited sectoral sanctions. With minor exceptions, Canada's imposition of travel bans and asset freezes relates to 38 individuals, companies and organizations previously designated by the United States and/or Europe. Similarly, Canada's sectoral sanctions targeted three financial institutions (Bank of Moscow, VTB Bank, and the Russian Agricultural Bank) previously named by the