The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued an advisory which clarified that the Transaction-Level Requirements, as defined in the CFTC Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations, are applicable to non-U.S. SDs that enter into swaps with a non-U.S. person if the swap is arranged, negotiated, or executed by personnel or agents of a non-U.S. SD located in the United States . According to the letter, the DSIO believes that the CFTC intended substituted compliance to be available, or for Transaction-Level

The CFTC Divisions of Clearing and Risk, Market Oversight, and Swap Dealer and Intermediary Oversight issued guidance to swap execution facilities ("SEFs") cautioning that the rules of various SEFs may be in conflict with the CFTC's requirement of "impartial access." Among the SEF rules or requirements that were mentioned by the CFTC as being problematic were (i) requiring that market participants have a pre-execution agreement, such as a breakage agreement, (ii) requiring that firms be either a swap dealer or a clearing member in order to see Requests for Quotes, (iii) limiting access to

The CFTC published final rules enhancing protections afforded customers and customer funds held by futures commission merchants ("FCMs") and derivatives clearing organizations ("DCOs") in the Federal Register. The new regulations amend existing regulations to require enhanced customer protection, risk management programs, internal monitoring and controls, capital and liquidity standards, customer disclosures, and auditing and examination programs for FCMs. The regulations also address certain related issues concerning DCOs and chief compliance officers. The effective date of these rules is

The Board of Directors of SIFMA announced that it has elected several new members to leadership positions on the Board for 2014. The new principal officers include: Jim Rosenthal, Chair; Bill Johnstone, Chair Elect; John Rogers, Vice Chair; and Bernard Beal, Treasurer. See: Newly Elected SIFMA Board of Directors.

The American Bankers Association ("ABA"), the Financial Services Roundtable ("FSR") and SIFMA submitted a joint letter to Senate Intelligence Committee Chair Dianne Feinstein (D-CA) and Ranking Member Saxby Chambliss (R-GA) urging the Senators to adopt "information sharing legislation" that would allow firms and the government to share information and coordinate efforts relevant to cybersecurity. The letter states that the financial service sector has made material investments to address cybersecurity issues, including enhancing the Financial Services Information Sharing and Analysis Center (