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The Asset Management Group ("AMG") submitted a number of requests to the CFTC asking that the CFTC extend compliance dates, preferably by interim rule or CFTC Interpretative Guidance, but, failing that, by no-action letter, and that it suspend or disapply certain of its rules as to FX and cleared block transactions. Delay in Business Conduct and Information Collection Rules. First, AMG requested that the effectiveness of the business conduct rules be suspended until November 1, 2013. According to AMG, firms simply will not be ready to comply by May 1 and, if the rules come into effect on that

The Asset Management Group (AMG) of SIFMA submitted the attached comment letter to the CFTC requesting that the Commission grant an extension of the compliance date for the reporting obligations under CFTC Rules Parts 43 (real time public reporting) 45 (swap data record keeping and reporting) and 46 (swap data record keeping and reporting for pre-enactment and transition swaps) applicable to non-swap dealers and non-major swap participants until October 10, 2013. SIFMA AMG stated that it agrees with other industry groups that many non-swap dealers and non-major swap participants have yet to

SIFMA and its European affiliate, the Association for Financial Markets in Europe ("AFME"), submitted the attached comments to the European Commission and the National Security Council urging the U.S. and EU to negotiate a comprehensive Transatlantic Trade and Investment Partnership ("TTIP") that includes for financial services the following: conventional market access rules, and a mechanism to ensure an efficient, cost-effective and compatible regulatory framework. The groups propose a framework for enhancing financial regulatory cooperation that would facilitate and guide efforts to promote

Michael S. Gibson, Director of the Division of Banking Supervision and Regulation of the Board of Governors of the Federal Reserve System, testified before the Senate Committee on Banking, Housing and Urban Affairs regarding the cross-border resolution of large financial firms. Gibson began by reviewing existing regulatory efforts to limit the cost to the broader financial system of a firm's systemic financial failure, noting in particular the progress made by the FDIC in implementing the Ordinary Liquidation Authority ("OLA"). Gibson went on to specify four remaining obstacles to making an