SIFMA, CME Group, Inc., the North American Tax Committee of ISDA, and the Futures Industry Association (the "Associations") submitted comments to the U.S. Treasury Department and the IRS requesting guidance on the application of existing rules treating swap upfront payments that constitute "significant" non-periodic payments, as loans for federal income tax purposes. According to the letter, in the context of cleared and many uncleared swaps, a party receiving an upfront payment is not entitled to retain the payment, but rather must remit the payment as variation margin back to the payor of

SIFMA and the Association for Financial Markets in Europe ("AFME") issued a joint statement applauding EU Commissioner Michel Barnier regarding his remarks relating to developments in U.S.-EU financial services and a Transatlantic Trade and Investment Partnership ("TTIP"). SIFMA and AFME emphasized the importance of coordination between the two jurisdictions as a key component of TTIP in order to "promote consistent high-quality regulatory standards in global markets and economies that are closely intertwined." Related news: U.S. and European Financial Services Trade Associations Issue Joint

The U.S. Treasury Department ("Treasury") issued a notice of proposed rulemaking to solicit public comment on proposed amendments to Treasury's rules for reporting large positions in certain Treasury securities. According to Treasury, the proposed amendments are designed to improve the information available to Treasury and simplify the reporting process for many entities subject to the large position reporting rules. Specifically, the proposed amendments Treasury's Large Position Report include: (i) revising the reporting format; (ii) requiring gross reporting; (iii) requiring reporting of

SIFMA submitted a letter to the Board of Governors of the Federal Reserve System, FDIC, the Office of the Comptroller of the Currency, the SEC, and the CFTC (the "Agencies"), informing the Agencies of the intention of certain financial institutions that are members of SIFMA to utilize joint ventures, as defined in Section __.10(c)(3) of the Volcker Rule, to share the income, gain, and loss on municipal bonds or other tax-exempt securities, commonly referred to as "tender option bond" programs. According to the letter, participants in joint ventures of this kind may include a banking entity or

Representative Maxine Waters (D-CA) wrote a letter to CFTC Chairman Timothy Massad, urging the CFTC to "thoroughly investigate" recent reports that large U.S. banks are attempting to avoid U.S. swap regulations by changing the swaps agreements of their foreign affiliates to remove explicit references to any guarantee by the U.S. bank. According to Rep. Waters, swaps transactions of foreign guaranteed affiliates transfer risk back to the United States to the same degree as if the transaction were entered directly by the U.S. bank, regardless of the form of the guarantee. Therefore, Rep. Waters