According to an MFA Blog post and a Reuters news item, Volker Bouffier, the Hesse state premier in Germany as well as deputy party leader to Chancellor Angela Merkel, stated his reservations about a financial transaction tax ("FFT") that will be enacted in Germany. Mr. Bouffier expressed his doubt by stating that the FFT would be a "unilateral move that would have devastating consequences for financial centers" in Germany See: MFA Blog Post; Reuters News Article.

The U.S. Treasury Department has once again revised the Model Intergovernmental Agreements ("IGAs") and their Annexes under FATCA and posted the revised versions on their website. There are at least three substantive changes. First, the revised IGAs now provide that equity and debt interests in an Investment Entity are considered "regularly traded on an established securities market" (and thus exempt from FATCA reporting) only if there is a "meaningful" volume of trading with respect to the interests on an ongoing basis on an exchange that is officially recognized and supervised by a

In his November 10th blog post, economist Craig Pirrong discussed the new CFTC position limits proposal. His commentary, linked below, notes that the new proposal has more sensible aggregation standards and permits the set-off of futures positions against swaps. That said, he closes by observing that the proposed rule is "unbelievably long," amounting to 533 pages and 846 footnotes, with "land mines" throughout. Lofchie Comment: Professor Craig Pirrong economic analysis of Position Limits may be briefly summarized as follows: (i) better than the original proposal, but (ii) still pretty bad and

The Alternative Investment Management Association ("AIMA") announced that Jack Inglis will be the organization's new CEO. Mr. Inglis will assume his role in the beginning of 2014. See: AIMA Press Release.

The European Securities and Markets Authority ("ESMA") published an updated version of its "Question and Answers" document ("Q&A") with a new question regarding the reporting of market-to-market value. The ESMA Q&A is intended to provide common supervisory approaches and practices in the application of European Market Infrastructure Regulation ("EMIR"). The questions are organized around three major topics: OTC issues generally, central counterparties and trade repositories. Lofchie Comment: The questions and answers document raises lots of interesting new questions for firms that are subject