The Municipal Securities Rulemaking Board ("MSRB") submitted a very thoughtful comment letter in response to the SEC's proposed Regulation Systems Compliance and Integrity ("Regulation SCI"). While the MSRB stated its support for many aspects of the proposed rule, its many detailed comments also highlighted the difficulties inherent in the SEC's attempt to create such an ambitious regulatory scheme out of whole cloth. According to the MSRB, these difficulties include that Regulation SCI is overly broad, impractical and ambiguous. See: MSRB Comment Letter S7-01-13. See also: Cadwalader Memo

The Delta Strategy Group released a summary of the Basel Committee on Banking Supervision's potential changes to the interim capital rules. Attached are the two June consultative reports released by the Basel Committee: The first consultative document suggests potential changes to the capital treatment of exposures to Qualifying Central Counterparties ("QCCPs");and The second consultative document describes a proposed method of calculating counterparty credit risk exposure called the non-­internal model method ("NIMM"). Separately, the OCC and Federal Reserve Board approved on July 2 final

The SEC announced on July 1, 2013, that it charged three individuals with insider trading in connection with the acquisition of Rohm Haas by Dow. The complaint alleges that one of the three charged individuals obtained the confidential information from his then live-in girlfriend, now his wife, who was the administrative assistant to Dow's CFO. However, the girlfriend/wife was not charged, as her failing seems to have been to not hide the relevant information from her boyfriend; there is no assertion that she was involved in the trading decisions. See: Click here to view the SEC Litigation

The NFA issued an interpretive notice regarding NFA Rules Section 16 ("FCM Financial Practices and Excess Segregated Funds/Secured Amount Disbursements"), which is designed to establish requirements regarding the maintenance of an FCM's residual interest in customer segregated funds, customer secured amount, and cleared swaps customer collateral accounts. The notice provides an analysis of Section 16 requirements and further regulatory measures that FCMs must adopt including: Requirements upon FCMs relating to certain withdrawals of their residual interest; FCMs must report certain financial

The NFA will adjust its assessment fee for Diminutive Notional Value Contracts ("DNVCs"). Specific policies that will apply include the following: The NFA assessment fee for DNVCs shall be $0.00008 per round-turn, with a minimum fee of $.01 per round-turn in the event that a customer trades less than 100 contracts. If any computation results in a fraction of a cent, the fee should be rounded to the nearest penny; In addition to adopting this fee, the Board has also at this time decided to adopt this fee structure for security futures products. The Effective Rule from September 1, 2012 (Revised