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Following the May 11, 2014 referendum in eastern Ukraine, the European Union ("EU") and Canada announced on May 12, 2014 that they had imposed sanctions on additional individuals and entities in connection with the ongoing crisis in Ukraine. The EU designations included 13 individuals and two entities - Chernomorneftegaz and Feodosia - the first companies to be targeted by the European Union. (The United Kingdom announced on May 13, 2014 that it had sanctioned the same 15 individuals and entities.) According to the European Union, both Chernomorneftegaz and Feodosia were "effectively

SIFMA submitted a comment to the Consumer Financial Protection Bureau ("CFPB") regarding the amendment to the annual privacy notice requirement under the Gramm-Leach Bliley Act ("GLB"), or Regulation P, requesting that the CFPB extend the 30-day comment period to a 90-day comment period. In the letter, SIFMA states that the proposed amendments to Regulation P may impose substantial operational and legal challenges related to the format and delivery of annual privacy notices, and therefore requires a longer comment period for more thorough analysis. See: SIFMA Letter to CFPB.

SEC Commissioner Gallagher issued a comment letter criticizing the authority of the Financial Stability Oversight Council ("FSOC") to designate nonbank entities as systemically important financial institutions ("SIFIs"). Commissioner Gallagher stated that although the SEC does not have a formal role in "FSOC's misguided debate" over whether or not to designate asset managers as SIFIs, he called on regulators and market participants to engage in an "honest debate" regarding FSOC initiatives. Commissioner Gallagher criticized the recent OFR Asset Management and Financial Stability Report, which

The SEC charged Rafferty Capital Markets ("Rafferty") with illegally facilitating trades for another firm that wasn't registered as a broker-dealer. According to the SEC Order, Rafferty agreed to serve as the broker-dealer of record in name only of approximately 100 trades in asset-backed securities that were actually introduced by an unregistered firm. While Rafferty held the necessary licenses and processed the trades, the unregistered firm managed the business. Though five of the firm's employees became registered representatives with Rafferty, they performed their work in the offices of

Bob Zwirb Commentary by Bob Zwirb

The Managed Funds Association ("MFA") submitted comments with the European Commission ("EC") in response to the EC's request for comments (in connection with a Consultation Document that the EC issued) on how to define a foreign exchange ("FX") spot contract and how to delineate between spot contracts and FX financial instruments, which are subject to other legal frameworks, such as Markets in Financial Instruments Directive II and the European Market Infrastructure Regulation. & The MFA recommended that the EC, in interpreting an "FX spot transaction" consider an approach comparable to the U