NFA Financial Requirements Section 16 became effective on September 1, requiring FCMs which hold customer segregated or secured amount funds to submit certain financial related information to NFA on a monthly, semi-monthly or daily basis. As of November 30, reporting requirements for residual interest targets and leverage information will change. Click here to view Notice in full (links externally to NFA website). See also: Related news story on NFA Financial Requirements Section 16.

ISDA published an analysis of initial margin (IM) requirements for non-centrally cleared OTC derivatives under current regulatory proposals. The analysis highlights three significant industry concerns. First, the level of IM required under the BCBS-IOSCO proposal is very significant, ranging from $1.7 trillion to $10.2 trillion depending on whether internal models or standardized schedules are used. Second, the increased amount of IM that would be required in stressed conditions will result in greatly increased demand for new funds at the worst possible time for market participants. This pro

ISDA submitted the attached no-action request to the CFTC on behalf of its members and other similarly situated persons with obligations under CFTC Swap Documentation Rules 23.502 (Portfolio Recognition) and 23.504 (Swap trading relationship documentation) asking that the compliance dates be pushed back to July 1, 2013. If approved, the relief would, among other things, allow market participants to delay entry into and compliance with "Protocol 2," the industry standard form being developed by ISDA (for which project Cadwalader serves as ISDA's counsel).

The German regulator BaFin released the attached materials regarding planned requirements under proposed high-frequency trading ("HFT") legislation, which included information on new rules that would be authorized by proposed legislation that the federal German government is considering. The required elements of the legislation would include the following: HFT traders would be required to be authorized by BaFin; HFT systems would be required to have effective risk controls including the following elements: their trading systems are resilient, have sufficient capacity and are subject to

The Federal Reserve Bank of New York (FRBNY) Executive Vice President Simon Potter delivered a speech on the role of central bank interactions with financial markets, focusing on the operational and market monitoring responsibilities of the New York Fed Markets Group and how these responsibilities have evolved since the onset of the financial crisis. Potter then discussed his role as a research economist trying to make sense of the crisis through the prism of economic theory. He concludes by stating that economic and finance education may need to be supplemented, in that analytic rigor of the