The SEC approved proposed rule amendments to FINRA Rules 2210 ("Communications with the Public") and 2214 ("Requirements for the Use of Investment Analysis Tools"). The amendments to Rule 2210 would: (i) exclude from the filing requirements research reports concerning only securities listed on a national securities exchange, other than research reports which must be filed pursuant to Investment Company Act Section 24(b) ("Registration of securities under Securities Act of 1933"), and (ii) clarify that free writing prospectuses that are exempt from filing with the SEC are not subject to the

The CFTC announced a 30-day extension of the comment period for the proposed rulemakings on position limits for physical commodity derivatives and aggregation of positions. The CFTC previously extended the comment period deadlines for the proposals until July 3, 2014. To provide commenters with sufficient time to respond to questions raised and points made at the June 19, 2014 roundtable on the two rulemakings, the CFTC is further extending the comment period for 30 days from the date of its publication in the Federal Register. The Position Limits Proposal establishes speculative position

The CFTC Division of Market Oversight issued a time-limited extension of the relief previously provided in CFTC Letter 13-41. The relief relates to reporting certain identifying information regarding counterparties in specific jurisdictions. The CFTC is extending the expiration of the relief provided in Letter 13-41, without modification to the original terms and conditions, until the earlier of: (i) the reporting party no longer holding the requisite reasonable belief regarding the privacy law consequences of reporting; or (ii) 12:01 a.m. EST on January 16, 2015. CFTC Letter 13-41 provided

Just days before the July 1 implementation date for FATCA, two countries, Saudi Arabia and China, reached agreements "in substance" with the United States with respect to an Intergovernmental Agreement ("IGA") to implement FATCA. Both countries agreed to a Model 1 type of agreement under which Chinese and Saudi financial institutions will be required to report information about accounts held directly or indirectly by U.S. persons to their respective home taxing authority, which will forward such information on to the U.S. IRS. It is unclear whether such agreements are reciprocal. Dominica

The SEC Division of Investment Management issued guidance to address how Advisers Act Rule 206(4)-2 ("The Custody Rule") applies when advisers to pooled investment vehicles utilize either special purpose vehicles when making investments ("Investment SPVs"), or escrow accounts when selling interests in portfolio companies. According to the SEC, inquiries regarding Investment SPVs commonly are focused on how the SEC's guidance applies to an investment adviser to pooled investment vehicles that rely on the audit provision. Inquiries regarding Escrow accounts commonly are focused on a circumstance