SIFMA Asset Management Group ("AMG") submitted comments to the European Commission ("EC") requesting a postponement of the European Market Infrastructure Regulation ("EMIR") reporting obligation to the buy-side. SIFMA AMG stated that it has substantial reservations regarding the operational feasibility for compliance from buy-side market participants, and explained that applying the Reporting Obligations to buy-side market participants before they have time to prepare may result in inaccurate reporting, which would impede the goal of creating a clear overview of the derivatives market

The Asset Management Group of SIFMA ("SIFMA AMG") and ISDA submitted comments to the CFTC requesting that the CFTC extend the comment period for the Aggregation Notice of Proposed Rulemaking in order to align it with the end of the comment period for the proposed rule regarding Position Limits for Derivatives. According to the comment letter, the two proposed rules were considered and adopted at the same CFTC public meeting on November 5, 2013. Therefore, the proposed rules are "deeply intertwined," and the agencies believe it is "essential to have sufficient time to review and comment on them

SIFMA issued its 2014 and 2015 recommended holiday schedules for full and early market closes for the trading of U.S. dollar-denominated fixed-income securities in the United States, the United Kingdom and Japan. SIFMA recommended early and full market closes, yet stated that each member firm should decide for itself whether its fixed-income departments remain open for trading. The recommendations apply to trading of U.S. dollar-denominated government securities, mortgage- and asset-backed securities, over-the-counter investment-grade and high-yield corporate bonds, municipal bonds, and

The Board of Governors of the Federal Reserve System ("FRB") invited public comment on proposed amendments to Regulation A ("Conditional Small Issues Exemption"). Regulation A amendments would implement Dodd-Frank Section 1101 ("Federal Reserve Act Amendments on Emergency Lending Authority"), which is designed to ensure that any emergency lending program or extension of credit authorized by the FRB is for the purpose of providing liquidity to the financial system, and not to aid an individual failing financial company. Comments must be submitted by March 7, 2014. See: FRB Request for Public

FINRA released updates to the Interpretations of Financial and Operational Rules to reflect the recommendations that the SEC Division of Trading and Markets made to FINRA. The updated interpretations consist of specified additions, revisions and rescissions that relate to Exchange Act Rules 15c3-1 ("Net Capital Requirements for Brokers or Dealers"), 15c3-1b ("Adjustments to Net Worth and Aggregate Indebtedness for Certain Commodities Transactions (Appendix B to Rule 15c3-1)"), 15c3-1d("Satisfactory Subordination Agreements (Appendix D to Rule 15c3-1)"), 15c3-3 ("Customer Protection - Reserves