IFLR.com Linked below are three articles that were published in the International Financial Law Review ("IFLR") and pertain principally to three recent CFTC regulations related to swap-execution facilities ("SEFs") and other recent CFTC SEF-related actions. Together, these provide an excellent prÉcis on the CFTC's May 2013 final regulations with respect to SEF core principles and other requirements, "Made Available to Trade" determinations and minimum block trade sizes, as well as some of the major related implementation and cross-border issues. "First Steps on the Path Forward" was co

The SEC released notification of an immediately effective FINRA filing which revises the content outline and selection specifications for the Investment Company and Variable Contracts Products Representative (Series 6) examination program. The SEC is soliciting comments which should be submitted on or before 21 days from publication in the Federal Register. We previously reported this FINRA rule filing on October 16, 2013. See: SEC Notice. See also: Text of Proposed Rule Change.

In his October 23 blog post, economist Craig Pirrong discusses the lack of clarity in CFTC rulemaking relating to SEFs (and other issues), in particular criticizing the CFTC's practice of adopting requirements that are contained in difficult to interpret footnotes. Lofchie Comment: In another news story about CFTC footnotes, Chairman Gensler was quoted as saying, "swap dealers must be careful how they interpret regulations." This is an interesting comment in two respects: (i) first, the whole point of the controversy over footnotes in CFTC regulations is that the market does not know what

According to an MFA blog post and Wall Street Journal news item, global rules that were designed to increase transparency in the swaps market worry the Hong Kong Monetary Authority. The new rules, which took effect earlier this month in the U.S., push derivative trades through central clearing houses and trade repositories. According to the blog post, the new rules would impact liquidity in Asia unless regulators agreed on a measure to make rules workable for their markets. Howard Lee, Executive Director of Monetary Management for the Hong Kong Monetary Authority, urged global lawmakers to

The Office of the Comptroller of the Currency ("OCC"), the Board of Governors of the Federal Reserve System ("Board"), and the Federal Deposit Insurance Corporation ("FDIC") proposed new rules to strengthen the liquidity positions of large financial institutions. The proposal would for the first time create a standardized minimum liquidity requirement for large, internationally active and systemically important banking organizations ( i.e., banking organizations with more than $250 billion in total assets or more than $10 billion in on-balance sheet foreign exposure, and to their consolidated