SIFMA submitted the attached comments to the CFTC requesting an extension of the time-limited, no-action relief for CPO registration in relation to securitization vehicles granted by CFTC letter 12-45. According to the "SIFMA" letter, a CFTC dialogue with market participants and industry representatives is ongoing. In addition to pending questions raised about the characterization of particular structures, securitization market participants continue to be actively engaged in discussions with the Division of Swap Dealer and Intermediary Oversight regarding the many respects in which the

The SEC charged the State of Illinois with securities fraud for misleading municipal bond investors about the state's approach to funding its pension obligations. According to the SEC, Illinois took multiple steps beginning in 2009 to correct process deficiencies and enhance its pension disclosures. The state issued significantly improved disclosures in the pension section of its bonds offering documents, retained disclosure counsel, and instituted written policies and procedures as well as implemented disclosure controls and training programs. The state designated a disclosure committee to

The CFTC has filed a brief with the U.S. Court of Appeals for the District of Columbia Circuit in connection with the appeal of the Investment Company Institute and the Chamber of Commerce of a federal district court's decision dismissing their challenge to CFTC amendments to Rule 4.5, which will require Registered Investment Companies ("RICs") trading in futures and swaps beyond a certain level to register as commodity pool operators ("CPOs") and be subject to certain data reporting requirements for CPOs. The CFTC amendments challenged by ICI also reinstate a trading threshold and marketing

The International Organization of Securities Commissions ("IOSCO") published comments received in response to its report on financial benchmarks today. The European Central Bank ("ECB") favored IOSCO's call for greater regulation in the production of benchmark rates. The ECB stated, however, that the principles IOSCO adopts must be commensurate with the risk associated with producing the benchmark to prevent imposing unnecessary burdens on rate contributors. The ECB also stated that, in order for regulatory reform to be effective, the rules must be uniformly applied internationally to prevent

As of March 11, 2013, swap dealers, major swap participants and private funds active in the swaps market are required to begin clearing five swap classes including index credit default swaps (CDS) and interest rate swaps that they entered into on or after March 11, 2013. The clearing requirement applies to newly executed swaps, as well as changes in the ownership of a swap. Non-financial entities hedging commercial risk are eligible to elect an exception from clearing. CFTC Chairman Gensler referred to this implementation as "one of the most significant Dodd-Frank reforms . . . [which] lowers