SIFMA submitted two parallel comment letters to FINRA regarding proposed amendments to FINRA Rule 4210 ("Margin Requirements") to establish margin requirements for transactions in the "to-be-announced" ("TBA") market. Both letters express SIFMA's opposition to the proposed maintenance margin requirement and note that, if implemented, it could lead to a fragmented market that put FINRA member firms at a disadvantage. Additionally, both letters make similar recommendations regarding the scope of the new requirements and suggest, among other things, a compliance date that is at least 18 months

SIFMA and the Financial Services Roundtable ("FSR") submitted comments to the SEC on its February 25, 2014, staff memorandum ("Memorandum") regarding dissemination of asset-level data as to asset-backed securities ("ABS"). The Memorandum suggested that issuers might use their websites to disseminate asset-level data and other offering information to investors and potential investors, as required under the SEC's proposed offering, disclosure and reporting requirements for ABS. SIFMA and FSR supported the disclosure of asset-level data with respect to some ABS asset classes; however, they urged

The SEC announced two separate cases against men who profited by insider trading on confidential information they had learned from their wives about Silicon Valley-based tech companies. The SEC alleged that Tyrone Hawk violated a duty of trust by trading after he overheard work calls made by his wife, a finance manager at Oracle Corp., regarding her company's plan to acquire Acme Packet Inc. Hawk also had a conversation with his wife in which she informed him that there was a blackout window for trading Oracle securities because Oracle Corp. was in the process of acquiring another company

FINRA published a proposed rule change to amend FINRA Rules 2210 ("Communications with the Public") and 2214 ("Requirements for the Use of Investment Analysis Tools") in the Federal Register. The rule change would amend Rule 2210 to exclude from the filing requirements any research reports concerning only securities listed on a national securities exchange, other than those which must be filed pursuant to Investment Company Act Section 24(b) ("Registration of Securities under Securities Act of 1933"). The proposed rule would also clarify that free writing prospectuses that are exempt from

The OTC Derivatives Regulators Group ("ODRG") released a report that identifies the current list of remaining cross-border implementation issues related to the global reform of OTC derivatives markets. The report includes a summary of the status of such issues, as well as a timetable for addressing them through a series of reports to the G20 Finance Ministers and Central Bank Governors over the course of 2014. The main focus of this initial report to the G20 was to address cross-border issues on which the ODRG is working in relation to developing approaches to the treatment of branches and