The IRS has finally published a draft of the long-awaited Foreign Financial Institutions ("FFI") Agreement under FATCA. FFIs not located in Model 1 IGA countries and most FFIs located in Model 2 IGA countries must enter into an FFI Agreement with the IRS prior to July 1, 2014 in order to be in compliance with FATCA. The draft agreement, which was published as part of IRS Notice 2013-69, sets forth the specific requirements for due diligence, withholding, information reporting and compliance that each FFI must satisfy. The IRS has promised that the draft Agreement will be finalized before the

NASAA reported to the Senate that state securities regulators are developing a streamlined multi-state review system to ease regulatory compliance costs on small companies attempting to raise capital under the JOBS Act. Title IV ("Small Company Capital Formation") of the JOBS Act required the SEC to adopt a rule, commonly referred to as "Regulation A+," to provide an exemption for certain offerings up to $50 million. These offerings would be exempt from SEC registration, but they would be subject to registration at the state level unless the securities were listed on a national securities

The SEC approved amendments to FINRA Rule 6750 ("Dissemination of Transaction Information") and TRACE dissemination protocols that provide for the dissemination of transactions in TRACE-eligible securities that are affected pursuant to Securities Act Rule 144A ("Private Resales of Securities to Institutions"). In addition, the SEC approved amendments to FINRA Rule 7730 to establish real-time and historic data sets for Rule 144A transactions. In a related rule filing, FINRA amended Rule 7730 to establish the fees for Rule 144A real-time and historic data at the same rates currently in effect

The CFTC approved an Order granting limited purpose swap dealer ("SD") designations to Cargill, Incorporated, and an affiliate, Cargill Financial Services International, Inc., making this the first time that limited purpose SD designations have been granted. Limited purpose designations involve circumstances in which the CFTC designates a person as an SD for one type, class, or category of swap or activities without that person's being considered a swap dealer for other types, classes, categories or activities. The CFTC will have regulatory oversight of their SD activities in connection with

The Office of the Comptroller of the Currency ("OCC") announced that it has designated Marietta Perkins as a Senior National Bank Examiner.The title is the highest honor attainable for national bank examiners who have distinguished themselves through high-quality performance and service. See: OCC Press Release.