The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued two separate no-action letters providing relief to two commodity pool operators ("CPOs") that requested exemptions regarding annual reports. CFTC Letter 14-22 provided no-action relief to a CPO of a commodity pool from CFTC Rule 4.7(b)(3) ("Relief Available to CPOs"), which requires that the CPO distribute to its participants, and file with the National Futures Association ("NFA"), an Annual Report within 90 days of the close of the Pool's fiscal year. Instead, CPO proposed to file a 13-month Annual Report for the Pool

The CFTC Division of Market Oversight ("DMO") reissued the FAQs on commodity options in an effort to address questions it has received regarding the Trade Option Form ("Form TO") filing process and the circumstances which trigger the filing requirement. The FAQ covers matters such as: (i) whether commodity options are "swaps" (generally yes), (ii) which commodity options qualify for the trade option exemption, (iii) what the regulatory requirements are that apply to trade options, and (iv) information as to completing Form TO. The CFTC noted certain trade option participants are required to

On February 26, the Chairman of the House Ways Means Committee, Dave Camp (R-Mich), released a draft Tax Reform proposal that would cut tax rates for both individuals and corporations and eliminate or modify many deductions and other tax expenditures. The proposal would set the maximum individual rate at 35% for individuals currently taxed at the 39.6% rate, and 25% for individuals who file jointly with income above $74,800 and below $464,200. The current 20% rate for most long-term capital gains and qualified dividends of individuals would be repealed but only 60% of such capital gains and

The SEC issued a no-action letter to provide relief to broker-dealers with respect to certain requirements under amendments to Exchange Act Rule 15c3-3 ("Customer Protection - Reserves and Custody of Securities") that become effective on March 3, 2014. The relief relates to the requirement that broker-dealers obtain prior written consent from a customer for programs ("sweep programs") where a customer's free credit balances in a securities account are "swept" to a money market mutual fund of an account at a bank where deposits are FDIC-insured. The amendments adopted on July 30, 2013 to the

The SEC issued a no-action letter stating that it will not take action against broker-dealers holding cash in a reserve account at a non-affiliated U.S. branch of a foreign bank in determining whether it maintains the minimum deposits required under new paragraph (e) of Exchange Act Rule 15c3-3 ("Customer Protection - Reserves and Custody of Securities"). On July 30, 2013, the SEC adopted amendments to the broker-dealer financial responsibility rules, including new paragraph (e)(5) to Rule 15c3-3, which places limitations on banks where a broker-dealer can deposit cash to meet its customer or