Rolston Anglin, the Cayman Islands Minister for Financial Services, has reportedly announced on the floor of the Cayman Legislative Assembly that the Cayman Islands Government will adopt a Model 1 type FATCA IGA with the U.S. Mr. Anglin also reportedly announced that the Government had decided to enter into a similar agreement with the U.K. and that final negotiations with the U.S. and the U.K. would conclude quickly. For a compilation of our news stories on FATCA, see "Current Topics - FATCA."
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Non-U.S. banks are reminded that the deadline for requesting the right to submit a "tailored" resolution plan is April 5, 2013.While the resolution plan (or "living will") itself is not due until December 31, 2013, non-U.S. banks that fail to submit a request for tailored plan status by the April 5th deadline must submit a comprehensive living will in December. The living will requirement applies to any non-U.S. bank with global assets of $50 billion or more that maintains a branch, agency office, or FDIC-insured bank subsidiary in the U.S. (referred to as "foreign banking organizations" or
The SEC Division of Investment Management released guidance on when the Investment Company Act or Rule 497 of the Securities Act requires an investment company to file interactive content posted via social media. Whether content must be filed depends on the content, context, and presentation of the information transmitted, with particular attention placed on the substance of the communication. Examples of communications that would and would not require filing appear below. Content That Does Not Require Filing An incidental mention of the investment company name or family of funds, e.g., "More
SIFMA published a comment letter submitted to the Federal Financial Institutions Examination Council (FFIEC) on the proposed guidance, Social Media: Consumer Compliance Risk Management Guidance . Addressing the FFIEC's question of other consumer protection laws and regulations that may be implicated by financial institutions' use of social media, SIFMA pointed out: "FINRA and the SEC's Office of Compliance and Inspections and Examinations have already published guidance on the use of social media. The social media guidance published by FINRA and the SEC is tailored to the specific regulated
SIFMA submitted a comment to the SEC in favor of NASDAQ OMX PHLX's ("PHLX") proposed amendment to Rule 1092, Obvious and Catastrophic Errors. Under the amended rule, in the event of a catastrophic error, if one of the parties to the options trade is a broker-dealer customer, the adjusted price of the trade would be compared to the limit price of the order. Whenever the limit price exceeds the adjusted price, the customer would have twenty minutes from the time notified to accept the adjusted price or else the trade would be nullified. SIFMA supported the amendment since nullification avoids