SIFMA, the Government Finance Officers Association, the National Association of Bond Lawyers and the Bond Dealers of America (the "Associations") submitted comments to the SEC regarding concerns with the current structure of the Division of Enforcement's Municipal Continuing Disclosure Cooperation Initiative ("MCDC"). The Associations provided the SEC with suggestions for modifications to the program in order to "maximize MCDC's potential to improve disclosure compliance, to increase participation in the initiative, and to provide the most accurate set of responses to the SEC," including

The House Financial Services Committee scheduled a markup for July 29, 2014 to consider six bills, including the Regulation D Study Act (H.R. 3240) (referring to Regulation D under banking law relating to deposits, not Regulation D under the Securities Act relating to private placements), the Federal Reserve Accountability and Transparency Act of 2014 (H.R. 5018) (the "Accountability Act"), and a bill to amend the Bank Holding Company Act of 1956 (H.R. 3913). Lofchie Comment: The Accountability Act would place a variety of constraints on the Federal Reserve, including that it conduct a cost

The SEC charged Lava Flow, Inc. ("Lava Flow"), an alternative trading system ("ATS"), with improperly disclosing its subscribers' confidential trading information to an affiliate. Regulations require an ATS to establish and enforce safeguards and procedures to protect the confidential trading information of its subscribers. According to the SEC's order, over the course of a three-year period, Lava Flow violated Regulation ATS Rule 301(b)(10) ("Requirements for Alternative Trading Systems") by allowing its affiliate, Lava Trading, Inc. ("Lava Trading") to access and use Lava Flow's customers'

The MSRB announced that it plans to provide free public access to public finance ratings from Kroll Bond Rating Agency on its Electronic Municipal Market Access ( EMMA) website. S ee: MSRB Press Release.

Ukraine-Related Developments Canada On Thursday July 24, 2014, Canada announced additional targeted sanctions against Russian and Ukrainian individuals and entities in connection with the ongoing crisis in Ukraine. Significantly, Canada followed the approach adopted by the United States last week by imposing sectoral sanctions on three large Russian companies in the financial and energy industries. The three companies, OAO Gazprombank, Vnesheconombank ("VEB"), and Novatek, were all named to the U.S. Sectoral Sanctions Identifications List on July 16. Canada did not designate Rosneft, Russia's