SIFMA submitted a comment letter to the U.S. Senate Agriculture Committee as to the reauthorization of the Commodity Exchange Act (CEA), and thus the reauthorization of the CFTC. SIFMA encouraged the Ag Committee to consider the impact of how regulators, specifically the CFTC, are interpreting and proposing to implement the Dodd-Frank Act, particularly as to cross-border transactions and as to swap execution facilities, as to margin requirements on OTC swaps and as to the regulation of swaps between affiliates. The letter also expressed concern about a number of issues outside of the control

Two IRS officials told a conference in New York City recently that the IRS is focused on preparing and finalizing guidance needed for U.S. withholding agents and foreign financial institutions to meet FATCA obligations that commence on January 1, 2014. Steve Musher, IRS Associate Chief Counsel (International), indicated, for example, that the terms of the foreign financial institution ("FFI") agreement that FFIs in non-Model 1 IGA countries must sign and final versions of registration and reporting forms should be published prior to the time that the FATCA registration portal opens on July 15

In a speech before the Investment Company Institute (ICI) General Membership, SEC Chair Mary Jo White echoed her fellow Commissioners' remarks from this past week, stating that the U.S. financial system requires the SEC to be global, and that the SEC must continue to match "regulatory and enforcement priorities with those of scores of jurisdictions around the world." Her speech addressed a good number of the topics, including the following: Cross-Border, The Mutual Fund Industry, Money Market Fund Regulation, Benefits of International Reach and Cooperation on Enforcement Actions, Fraud and

FINRA filed with the SEC a proposed rule change to establish September 3, 2013, as the implementation date of FINRA Rule 5270 ("Front Running of Block Transactions") that the SEC approved on September 4, 2012. The proposed rule change adopted NASD Interpretive Material 2110-3 ("Front Running Policy") asFINRA Rule 5270 with certain changes, including broadening the rule's scope and providing further clarity into trading activity that FINRA believes is impermissible. [Subscriber links appear in the preceding sentence.] See : Text of Proposed Rule Change.

FINRA RN 13-18 provides new guidance on communications with the public concerning non-traded REITs and DPPs. The notice was drafted by the FINRA advertising department and likely brings to a conclusion an extended series of recent FINRA reviews of industry marketing materials. A summary is below. The Regulatory Notice is effectively an interpretation of FINRA Rule 2210, which requires that FINRA member communications with the public be "fair, balanced and not misleading." (For a general discussion of the requirements applicable to broker-dealer communications, see Lofchie's Guide to Broker