The Managed Funds Association ("MFA"), the American Council of Life Insurers ("ACLI"), and the Alternative Investment Management Association ("AIMA") (collectively, the "Associations") submitted a joint follow-up letter requesting that the SEC address buy-side concerns related to the customer margin regime for the cleared credit default swaps ("CDS") portfolio program. Upon expiry of the temporary customer initial margin regime as of January 31, 2014, the SEC will require each clearing member of ICE Clear Credit to have its own individual customer margin methodology. The new methodology must

In three separate no-action letters, the SEC Division of Investment Management granted an extension of no-action relief under Investment Company Act Section 17(f) ("Custody of Securities") to any registered investment company that maintain assets in the custody of ICE Clear Credit LLC, LCH.Clearnet Limited ("LCH"), LCH.Clearnet, LLC, and Chicago Mercantile Exchange ("CME"). The SEC originally granted relief regarding these clearing agencies in three separate letters dated September 27, 2012, which stated that the SEC would not recommend action under Investment Company Act Section 17(f) against

The SEC issued a guidance update regarding Charitable Investment Funds that are separate legal entities organized and operated for investment purposes. The SEC staff recently was asked to clarify the exclusion that may be available to Charitable Investment Funds that act as a legal entity separate from the charitable organization that maintains it, and that is organized and operated for the purpose of earning investment returns for the investing charitable organizations, which are to be used exclusively for charitable purposes of specified types ("Permitted Purposes"). The SEC stated that a

The SEC has adopted amendments that remove references to nationally recognized statistical rating organizations ("NRSROs") credit ratings in certain rules and forms. The changes were required by Dodd-Frank, and remove credit rating references from: Investment Company Act Rule 5b-3 ("Acquisition of Repurchase Agreement or Refunded Security Treated as Acquisition of Underlying Securities"): a rule that permits funds to look through repurchase agreements to the underlying collateral securities for certain counterparty limitation and diversification purposes provided the collateral meets certain

The National Futures Association ("NFA") issued a Notice reminding members that the New Year's Day holiday will impact regulatory filings. Additionally, NFA posted a complete schedule of filings for the upcoming 2014 holidays, as well as an updated calendar for due dates of Segregated Investment Detail Reports ("SIDRs"). New Year's Day will impact regulatory filings as follows: Daily segregated, 30.7 secured, cleared swaps customer collateral and daily forex statements prepared as of December 31, 2013 are required to be submitted by 12:00 noon on January 2, 2014; Daily segregated, secured and