SIFMA has submitted comments to the SEC regarding the FINRA-proposed rule to begin dissemination of data for transactions in asset-backed securities ("ABS") and non-Agency Commercial Mortgage Backed Security ("CMBS"). The rule proposal would implement shorter "reporting timeframes for ABS transactions, and real-time dissemination of trade information. Additionally, the proposal would amend the definition of "ABS." In the letter, SIFMA stated that its members agree with FINRA regarding benefits to price discovery as a result of shorter timeframes for disseminating information. However, SIFMA

At the Federal Republic of Germany in Berlin, SEC Commissioner Daniel M. Gallagher delivered a speech regarding the impact of post-global regulatory reforms on financial markets, with a specific focus on what he referred to as "the trend towards so-called 'regulatory harmonization.'" According to Commissioner Gallagher, the legislative response to the 2008 global financial crisis, the Dodd-Frank Act, really had nothing to do with the crisis at all. The fact that Dodd-Frank was enacted before the completion of the Commission's investigation of the causes of the crisis, Gallagher stated, is the

The SEC has proposed rules intended to increase access to capital for smaller companies pursuant to the JOBS Act. The proposed rules would update the Regulation A "Conditional Small Issues Exemption," which currently provides an exemption from registration for small offerings of securities up to $5 million within a 12-month period. The updated exemption would expand Reg. A by creating two tiers of Reg. A offerings: Tier 1, which would consist of those offerings already covered by Reg. A - namely, securities offerings of up to $5 million in a 12-month period, including up to $1.5 million for

The National Futures Association ("NFA") has issued a notice to its members regarding how the Christmas holiday will impact regulatory filings. The NFA stated that the regulatory filing schedule is as follows: Daily segregated, 30.7 secured, cleared swaps customer collateral and daily forex statements prepared as of December 24, 2013 are required to be submitted by 12:00 noon on December 26, 2013; Daily segregated statements are not required to be prepared as of December 25, 2013; Daily 30.7 secured, cleared swaps customer collateral and forex statements are required to be prepared as of

The Government of Malta announced that it has entered into a Model 1A (Reciprocal) Intergovernmental Agreement ("IGA") with the United States. Under the terms of the IGA, each country agrees to collect and turn over to the other country its information on accounts maintained within its borders by residents of that other country. In connection with signing the IGA, Malta announced that it would soon be announcing a voluntary disclosure plan for residents of Malta to file and pay taxes that have not previously been reported before disclosure begins under the IGA. The text of the IGA has not yet