Nearly 100 countries signed FATCA Intergovernmental Agreements ("IGAs") or agreed in substance to the terms of such an agreement prior to the July 1, 2014 implementation date of FATCA. The IRS announced that any country that agreed in substance to the terms of an IGA on or before June 30, 2014 would be treated as having an IGA in effect at least through December 31, 2014. The vast majority of jurisdictions elected to enter into a Model 1 type IGA under which financial institutions in such jurisdictions will provide information on direct or indirect U.S. account holders directly to their local

On June 27, 2014, the Financial Action Task Force ("FATF") issued a report providing a general framework for understanding and addressing the anti-money laundering / countering the financing of terrorism ("AML/CFT") risks associated with virtual currencies such as Bitcoin. Building on its 2013 New Payment Products and Services ("NPPS") Guidance, the FATF report proposes a common set of definitions that can be adopted by government officials, law enforcement and private sector entities to reflect accurately the different forms that virtual currencies may take. The report also lays out the

FINRA announced that it fined Goldman Sachs Execution Clearing, L.P. ("Goldman Sachs") for failing to establish, maintain and enforce written policies and procedures that were reasonably designed to prevent trade-throughs of protected quotations in NMS stocks. This action pertains to Goldman Sachs' trading in its proprietary alternative trading system ("ATS"). The Order Protection Rule generally requires that trading centers either trade at best-quoted prices or otherwise route orders to the trading centers quoting the best prices. FINRA found that, from July 29, 2011 through August 9, 2011

The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the National Credit Union Administration issued guidance to financial institutions regarding home equity lines of credit ("HELOCs") nearing their "end-of-draw" periods, which occur when the principal amounts of the HELOCs must begin to be repaid. See: Interagency Guidance on Home Equity Lines of Credit Nearing Their End-of-Draw Periods. See also: FRB Press Release; OCC Press Release; FDIC Press Release.

The National Futures Association ("NFA") issued a notice to remind members of the obligations of swap dealers ("SDs") and major swap participants ("MSPs") following the departure of chief compliance officers ("CCOs"). According to the notice, CFTC Rule 3.3 requires each SD and MSP to designate an individual to serve as its CCO. Upon the departure of a CCO due to resignation or replacement, an SD or MSP is required to submit a Form 8-R identifying the new CCO as a principal of an SD or MSP. The SD or MSP should update the compliance contact in the NFA's Online Registration System. Additionally