William Dudley, president of the Federal Reserve Bank of New York, gave a speech at the Clearing House's Annual Business Meeting titled "Solving the Too Big to Fail Problem". Dudley stated the problem in two parts: (i) whether society should tolerate a financial system in which certain financial institutions are deemed to be too big to fail, and (ii) if not, what we should do about it. To the first question, Dudley stated that the answer is "clearly" that "we cannot tolerate a financial system in which some firms are too big to fail--at least not ones that operate in any form other than that

The MSRB has revised the study outline for the Municipal Securities Principal Qualification Examination (Series 53). The Series is designed to determine whether an individual meets the MSRB's qualification standards for a municipal securities principal. The revisions remove rescinded rules and include amendments and additions to the MSRB's rules. Series 53 examinations based on the revised study outline will commence on December 22, 2012. View Study Outline in full here (links externally to MSRB website). See also: MSRB Notice.

The SEC issued its second annual staff report on the findings of examinations of credit rating agencies registered with the SEC as Nationally Recognized Statistical Rating Organizations ("NRSROs"). The staff determined that, with one exception, all NRSROs appropriately addressed the staff's recommendations in the first annual report in 2011. The 2012 report discusses the staff's findings and recommendations in eight areas, including whether the NRSRO conducts business in accordance with its policies, procedures, and methodologies, how it manages conflicts of interest, and whether it maintains

The Director of the SEC's Division of Enforcement, Robert Khuzami, delivered remarks during news briefing about the SEC-DOJ FCPA Guide. According to Director Khuzami, the SEC should reward companies that adopt compliance programs which are effective in preventing violations, and the SEC is not going after the "$5 cup of coffee, or the one-off $50 gift to a public official . . . but payments of real and substantial value that clearly represent an unambiguous intent to bribe a foreign official to obtain or retain business." View remarks in full here (links externally to SEC website). See also

The U.S. Treasury Department publicly released its Model 2 FATCA Intergovernmental Agreement ("IGA"). Under the terms of the Model 2 IGA, financial institutions located in jurisdictions that enter into a Model 2 form of IGA will be required, at the direction of the foreign government, to register directly with the IRS by January 1, 2014, and to report information with respect to U.S. accounts and with respect to accounts held by Nonparticipating Financial Institutions. Foreign governments entering into a Model 2 IGA would agree, upon request of the IRS, to obtain and exchange certain