The Government Accountability Office ("GAO") issued testimony that was delivered by the Director of Financial Markets and Community Investment, Lawrance Evans, before the Senate Subcommittee on Financial Institutions and Consumer Protection. The testimony focused on a November 2013 GAO report that discussed issues related to government support for large bank holding companies. The federal government maintains programs, frequently referred to as "safety nets," to reduce the vulnerability of depository institutions that could threaten the health of the banking system and the broader economy

IOSCO and the Financial Stability Board ("FSB"), each of which is an international coalition of national financial regulators, published a consultative document which proposes a high-level framework and specific methodologies for identifying non-bank non-insurer ("NBNI") global systemically important financial institutions ("SIFIs"). According to the FSB and IOSCO release, SIFIs are institutions whose distress or disorderly failure, because of their size, complexity and systemic interconnectedness, would cause significant disruption to economic activity and the wider financial system. At the

FINRA issued an information notice that includes the 2014 due dates for firm filings of Annual Audit, Financial and Operational Combined Uniform Single ("FOCUS") Reports, Form Custody, and FINRA-required supplemental FOCUS Report information, which includes a Supplemental Statement of Income ("SSOI") as well as Off-Balance Sheet ("OBS") Reports. According to the notice, all filings must be received by FINRA by their required due dates in order to avoid penalty fees and/or the suspension of a firm's FINRA membership. See: FINRA Information Notice.

FINRA filed a proposed rule change with the SEC to extend the expiration date of FINRA Rule 0180 ("Application of Rules to Security-Based Swaps") to February 11, 2015. FINRA Rule 0180 limits, with certain exceptions, the application of FINRA rules with respect to security-based swaps. Lofchie Comment: The extension indicates that the SEC is absorbing the lesson of the CFTC's difficulties in adopting a full set of rules that work. Perhaps under new leadership and with its recent request for comments on at least some of its interpretations, the CFTC will take the opportunity afforded by the

The Tax Section of the New York State Bar Association sent a 63-page report to the Treasury Department and IRS suggesting changes and clarifications that should be made to the final Foreign Financial Institution ("FFI") Agreement and to Intergovernmental Agreements ("IGAs") entered into between the United States and foreign countries. One of the thirty recommendations made by the Tax Section is that an FFI Agreement may only be terminated if there are multiple "material failures" by the FFI to meet its obligations under the Agreement, and that a Participating FFI should only be considered in