The SEC published final rules and guidance regarding definitions for "Security-Based Swap Dealer" and "Major Security-Based Swap Participant." The rules and guidance apply to cross-border security-based swap ("SBS") activities and were published in the Federal Register. In addition to the final rules and interpretation, the SEC adopted procedural rules relating to the submission of applications for substituted compliance, as well as a final rule addressing the scope of its authority regarding enforcement proceedings under Dodd-Frank Section 929P ("Unlawful Margin Lending"). The new rules focus

SIFMA submitted comments to the Board of Governors of the Federal Reserve System ("FRB") regarding proposed Regulation XX, which involves concentration limits on large financial companies. Regulation XX will implement Section 14 of the Bank Holding Company Act, which was added by Section 622 of Dodd-Frank. Section 14 provides that a financial company may not engage in a "covered acquisition" of another financial company if the total liabilities of the acquiring company would, following the acquisition, exceed 10% of the aggregate liabilities of all financial companies. The FRB's proposed rule

The Asset Management Group of SIFMA ("SIFMA AMG") submitted a letter to CME Group regarding the potential negative impact of the recently issued Joint Audit Committee ("JAC") alert on SIFMA members, their clients and the asset management business as a whole. The JAC Regulatory Alert 14-03 was intended to serve as a reminder to futures commission merchants ("FCMs") of certain margin policies related to the receipt of margin deposits and the release of excess margin funds. SIFMA AMG requested that the JAC withdraw certain provisions of the alert that could impact negatively "beneficial owners"

The FINRA proposal to extend the implementation of FINRA Rule 4240 ("Margin Requirements for Credit Default Swaps") until July 17, 2015 was published in the Federal Register and is effective immediately. FINRA Rule 4240 implements an interim pilot program with respect to margin requirements for certain transactions in credit default swaps that are security-based swaps. In the absence of an extension, the rule would expire on July 17, 2014. While the rule was deemed noncontroversial by the SEC and is effective immediately, comments on the proposal may be submitted until July 30, 2014. See: 79

FINRA filed with the SEC a proposed amendment to FINRA Rule 9620 to permit FINRA staff to provide written decisions for exemptive relief under NASD Rule 1070 ("Qualification Examinations and Waiver of Requirements") for members electronically. See: Text of the Proposed Rule.