The attached Appendix A provides a summary of the haircuts required to be taken in computing the capital value of various securities. Lofchie Comment: Be aware that the summary of the net capital haircuts omits quite a bit of material information. For example, the summary says that the haircut on equities is generally 15% - which is true - but says nothing about the fact that many unlisted or non-U.S. equities receive a 100% haircut. View Summary here (links externally to NFA website).

The Office of the Comptroller of the Currency ("OCC") is clarifying certain provisions of the market risk capital rule primarily related to sovereign debt positions. Lofchie Comment: The OCC is trying to avoid making it more expensive for banks to hold foreign sovereign debt obligations as well as certain related obligations, such as obligations issued by foreign banks. View bulletin here (links externally to OCC website).

The NFA issued a revised version of its self-examination questionnaires for FCMs, FDMs, IBs, CPOs and CTAs. NFA member firms are required to complete relevant sections of these questionnaires on an annual basis. The revised version of the Questionnaire incorporates revisions to the CPO Supplemental Questionnaire to update Form PQR reporting requirements to reflect recent amendments to NFA Compliance Rule 2-46 (see p. 35 of the Questionnaire). For further guidance on the revised Form PQR reporting requirements, see the Cadwalader News article, attached here. For ease of reference, we set out

SIFMA's amicus brief addresses: (1) whether the Securities Litigation Uniform Standards Act ("SLUSA") precludes a state-law class action alleging a scheme of fraud that involves misrepresentations about transactions in SLUSA-covered securities; and (2) whether SLUSA precludes class actions asserting that defendants aided and abetted SLUSA-covered securities fraud when the defendants themselves did not make misrepresentations about the purchase or sale of SLUSA-covered securities. Click hereto view brief in full (links externally to SIFMA website).

The U.S. Treasury Department has posted on its website updated drafts of both Model 1 and Model 2 Intergovernmental Agreements ("IGAs") under FATCA. There are three separate versions of Model 1: Model 1A (Reciprocal), Model 1B (Non-Reciprocal), for countries with pre-existing tax treaties or Tax Information Exchange Agreements ("TIEAs") with the United States, and a new Model 1B (Non-Reciprocal), for Countries without a current tax treaty or TIEA with the United States. Likewise, Model 2 comes in two versions, one for countries with an existing tax treaty or TIEA with the United States, and