Federal Reserve Governor Jerome H. Powell gave a speech at the Institute of International Bankers' Annual Washington Conference assessing U.S. and global regulatory efforts to end "too big to fail." Governor Powell stated that such efforts must involve waging a "two-front war": First, there must be enhanced regulation to make large financial institution failures much less likely and, second, there must be a credible mechanism to manage the failure of large firms without causing or amplifying a systemic crisis. Governor Powell went on to survey existing efforts on both of these fronts

FINRA Rule 4524 (Supplemental FOCUS Information) requires each firm to file additional financial or operational schedules or reports. The SEC has approved the adoption of a supplemental schedule for derivatives and other off-balance sheet items ("OBS") that applies to carrying or clearing firms. Th e initial OBS disclosing a carrying or clearing firm's off balance sheet information, as of June 30, 2013, must be filed with FINRA on or before July 31, 2013. The OBS can be found in the regulatory notice attached below. Implementation Date: The initial supplemental schedule disclosing off-balance

The International Organization of Securities Commissions ("IOSCO") published its final report of guiding principles for managing liquidity risk in a collective investment scheme ("CIS"). The report suggests ways in which a CIS can create, implement and monitor liquidity policies to ensure that the CIS meets its general redemption obligations. Specifically, the report makes the following recommendations: When creating a new CIS, its sponsor must be able to demonstrate to its regulator that it can comply with applicable local liquidity rules (if they exist); Where the CIS intends to invest in a

FINRA announced that it has fined Ameriprise Financial Services, Inc. and its affiliated clearing firm $750,000 for failing to have reasonable supervisory systems in place to monitor wire transfer requests and the transmittal of customer funds to third-party accounts. FINRA found that the firms did not have policies and procedures to detect multiple transmittals of funds going to third-party accounts, and did not adequately track previously rejected wire transfer requests. In addition, the firms failed to detect a former Ameriprise registered representative's misconduct despite numerous

CFTC Chairman Gary Gensler delivered remarks before the Institute of International Bankers’ ("IIB") Annual Washington Conference regarding matters on the CFTC's agenda that Gensler believes will be of importance to the IIB. Chairman Gensler repeated his prior criticisms of LIBOR as well as his description of Dodd-Frank as being "common-sense rules of the road" for the swaps market. Lofchie Comment: Whether the Dodd-Frank swap rules are good or bad, they can not be fairly described as "common-sense rules." They are immensely complicated, likely to discourage business, often inconsistent, and