The Office of the Comptroller of the Currency ("OCC") invited comment on proposed amendments to the OCC's Annual Stress Test rule that would shift back the timing of the annual stress test cycle by approximately 90 days. Additionally, the amendments would clarify that institutions covered by the Annual Stress Test rule will not have to calculate their regulatory capital ratios using the Basel III advanced approaches until the stress testing cycle beginning January 1, 2016. Comments are due 60 days after publication of the proposed rule in the Federal Register, which is expected shortly. See

The Office of the Comptroller of the Currency ("OCC") issued interim procedures for examiners to assess banks' progress in developing a framework to comply with the requirements of Dodd-Frank Section 619 ("Prohibitions on proprietary trading and certain relationships with hedge funds and private equity funds"), or the Volcker Rule, and the implementing regulations adopted by the OCC with the other rule-writing agencies. According to the OCC, these interim examination procedures were developed to help examiners understand and focus on the Rule's key aspects, as well as to work with banks during

The U.S. Treasury Department ("Treasury") revised the Annex I to the Model 1 and Model 2 Intergovernmental Agreements ("IGAs") under FATCA. Annex I contains reasonably simplified due diligence procedures that Foreign Financial institutions ("FFIs") in IGA countries must follow to determine the direct and indirect U.S. owners. Generally, the due diligence procedures in Annex I differ depending on whether the account was opened prior to July 1, 2014 (a "preexisting account") or on or after that date (a "new account") and whether the account holder is an individual or an entity. In Notice 2014-33

The IRS published a revised version of Publication 5124, the technical user guide for electronic FATCA reporting. According to the IRS, the updated user guide provides clarifications and minor updates to the original version that was issued in March 2014. Foreign Financial Institutions that report account information directly to the IRS must file Form 8966. The user guide explains how to prepare an electronic filing of Form 8966 and the information required to be included in each element of FATCA XML Schema v1.0. See: FATCA User Guide; Form 8966. See also: Cabinet FATCA Materials (for Cabinet

ISDA released a draft response to ESMA's discussion paper on position limits and reporting for MiFID commodities. Comments on the draft response must be submitted by June 23, 2014. See: Draft Response.