The FDIC has issued final supervisory guidance to FDIC-supervised financial institutions which is intended to ensure that banks are aware of the credit, reputational, operational and compliance risks associated with deposit advance products and have taken steps to effectively mitigate those risks. Deposit advance products are a type of small-dollar, short-term credit product that some depository institutions offer to customers maintaining a deposit account, reloadable prepaid card or similar deposit-related vehicle. The guidance supplements the FDIC's existing guidance on payday loans and

Andrew Ceresney, Co-Director of the SEC Division of Enforcement ("DOE"), delivered the keynote address at the 30th International Conference on the Foreign Corrupt Practices Act ("FCPA"). Mr. Ceresney explained that, over the past 10 years, the SEC has greatly increased its FCPA enforcement, and noted in particular the DOE's development of a specialized unit devoted to investigating FCPA violations three years ago. Since the development of the FCPA unit, the SEC has filed over 40 FCPA actions and recovered over $240 million in disgorgement penalties. While there has been progress, Mr. Ceresney

The Senate Finance Committee held a hearing to consider nominee for Deputy Secretary of the Treasury, Sarah Bloom Raskin, and nominee for Commissioner at the International Trade Commission ("ITC"), Rhonda Schmidtlein. The nominations were supported by Finance Committee Chairman Max Baucus (D-MT) and Senator Orrin Hatch (R-UT). The Finance Committee is expected to vote on the nominations in the beginning of December. See: Baucus Statement; Hatch Statement; Testimony of Deputy Secretary Nominee Raskin.

The SEC announced fraud charges against two Tampa-area investment advisers accused of failing to inform clients truthfully about compensation received from offshore funds. The advisers recommended the funds as safe investments despite substantial risks and red flags. The SEC's Enforcement Division alleged that Gregory J. Adams and Larry C. Grossman solicited and directed the clients of their investment firm, Sovereign International Asset Management, to invest almost exclusively in funds controlled by an asset manager named Nikolai Battoo, whom the SEC has previously charged in a separate

ISDA has supplemented its August 28, 2013 letter to Treasury and the IRS relating to so-called "Limited Life Debt Investment Entities" and its June 11, 2013 letter to Treasury addressing the treatment of posted collateral under an Intergovernmental Agreement ("IGA"). In this new letter, the ISDA reiterates its request that most securitization vehicles be exempt from any Expanded Affiliated Group because financial institutions may not be able to identify those securitization vehicles in which they may own more than 50% of a class of interests. Under the Final Regulations, if a securitization