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Six federal agencies - including the Board of Governors of the Federal Reserve System, Department of Housing and Urban Development, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Office of the Comptroller of the Currency, and the SEC - issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule which the agencies issued in 2011 to implement the risk retention requirement in Dodd-Frank. Linked below is a description of the re-proposal prepared by the Structured

The CFTC released the FY 2013 Schedule of Fees. The CFTC charges fees to designated contract markets and registered futures associations to recover the costs incurred by the CFTC in the operation of its program of oversight of self-regulatory organization rule enforcement programs - specifically the National Futures Association, a registered futures association - and the designated contract markets. The calculation of the fee amounts charged for FY 2013 is based upon an average of actual program costs incurred during FY 2010, 2011, and 2012. Effective Date: Each SRO is required to remit

The SEC Office of Compliance Inspections and Examinations ("OCIE") issued a Risk Alert, on business continuity and disaster recovery planning for investment advisers, which was prompted by a review of responses to Hurricane Sandy. The alert follows a joint advisory issued on August 16 by OICE, the CFTC's Division of Swap Dealer and Intermediary Oversight, and FINRA; however, this Risk Alert focuses exclusively on investment advisers. The alert makes observations in the following areas: Preparation for widespread disruption; Planning for alternative locations; Preparedness of key vendors

Bob Zwirb Commentary by Bob Zwirb

SIFMA Asset Management Group ("SIFMA AMG") submitted comments to the CFTC requesting interpretive guidance with respect to the status of certain types of FX transactions as bona fide spot foreign exchange transactions. The CFTC further defined the term "swap," setting forth a distinction between FX spot transactions and FX forwards that included providing guidance as to "securities conversion transactions," which are entered into in connection with a related foreign securities transaction. Additionally, SIFMA AMG submitted comments to the CFTC requesting relief for certain External Business

The United Kingdom recently issued an updated version of its Guidance Notes for the Implementation of the FATCA Intergovernmental Agreement ("IGA") with the United States. The revisions to the 142-page document essentially reflect the delayed effective dates under FATCA announced by the U.S. Treasury on July 12, 2013, as well as modifications to Annex II to the IGA. The Guidance Notes also provide that if the United States subsequently amends the underlying FATCA Regulations (which is likely) to introduce additional or broader exemptions, the UK will consider whether to incorporate these