The Coalition for Derivatives End-Users published a survey indicating that margin requirements froM& Dodd-Frank would adversely impact end-users, emphasizing the costs of margin requirements on end-users and the potential negative impact on employment. The survey provided a quantitative look into companies' utilization of Over-the-Counter ("OTC") derivatives, Centralized Treasury Unit ("CTU") usage, and the effect a margin requirement would have on companies’ abilities to manage business uncertainty. Additionally, it considers how companies are impacted by new reporting burdens and

The National Futures Association ("NFA") announced the addition of two new tutorial videos to its library of member education materials. The first, "How to File an Exemption through NFA's Electronic Exemption System," provides Commodity Pool Operators ("CPOs") and Commodity Trading Advisors ("CTAs") with a step-by-step guide on where to find the electronic exemptions system and instructions on how to navigate the system. The second, "How to Avoid Common PQR Filing Deficiencies," summarizes the new PQR filing requirements for CPOs and highlights areas of the filing process where the NFA has

The IRS published the long-awaited final version of Form W-8BEN-E on Friday, March 28. The eight-page form will be used by foreign entities to certify their FATCA status to banks, financial institutions and other withholding agents. Each foreign entity that completes the Form must certify its FATCA status from among 31 possible FATCA classifications. These include Participating FFIs, Reporting Model 1 FFIs, Reporting Model 2 FFIs, various categories of registered deemed-compliant FFIs and certified deemed-compliant FFIs, exempt entities, and various categories of non-financial foreign entities

FINRA published a proposed rule change to adopt FINRA Rule 2243 in the Federal Register. The proposed rule change would establish disclosure and reporting obligations related to member recruitment practices when a representative changes firms and attempts to recruit certain customers from the representative's prior firm. Comments on the proposed rule change must be received by April 18, 2014. Lofchie Comment: This is one FINRA-proposed rule change on which firms should comment. See: 79 FR 17592. Related news: FINRA Proposes to Adopt Rule Regarding Member Recruitment Practices Disclosure (March

FINRA published an immediately effective rule proposal to extend a pilot program related to FINRA Rule 11892 ("Clearly Erroneous Transactions in Exchange-Listed Securities") in the Federal Register. FINRA proposes to extend the pilot program to coincide with the pilot period for the Plan to Address Extraordinary Market Volatility, pursuant to Reg. NMS Rule 608 ("Filing and Amendment of National Market System Plans"), known as the "Limit Up-Limit Down Plan." Comments on the proposed rule change must be received by April 18, 2014. See: 79 FR 17615. Related news: FINRA Proposes Rule to Extend the