The SEC announced that it is authorized to treat records as not subject to the requirements of the FOIA under the following three circumstances: (c)(1) Exclusion: Where the subject of a criminal investigation or proceeding is unaware of the existence of records concerning a pending investigation and disclosure of such records would interfere with the investigation. (c)(2) Exclusion: Where there are informant records maintained by a criminal law enforcement agency and the individual's status as an informant is not known. (c)(3) Exclusion: Where there are classified FBI records pertaining to

The SEC-OIG published a final report detailing the results of the SEC's records management practices (as part of the continuous effort to assess management of the Commission's programs and operations). The objectives were to examine whether (1) the Office of Records Management Services (ORMS) established a viable records management program that ensures permanent SEC records are appropriately maintained and preserved in accordance with applicable Federal statutes and regulations, and (2) ORMS adhered to applicable Federal statutes and regulations regarding the retention, disposal, transfer and

SIFMA's Asset Management Group submitted this comment letter to the CFTC expressing concerns regarding the clearing mandate of certain interest rate swaps and credit default swaps, suggesting that the clearing mandate is premature. SIFMA notes that, despite the intensive efforts of market participants, "the volume of legal documentation required for compliance with the customer clearing rules makes it unlikely that the industry will be ready in time for the compliance dates triggered by this first clearing determination." Cross-Reference(s): Commodity Exchange Act Section 2(h) (Jurisdiction of

SIFMA's Asset Management Group (AMG) submitted the attached comment letter to the CFTC, OCC, Federal Reserve Board, FDIC, FCA, FHFA and BCBS/IOSCO regarding margin requirements for uncleared swaps for SDs and MSPs. The letter covers a wide variety of topics from the scope of applicability of the margin rules, margin calculation procedures, eligible collateral, handling of collateral, trading with affiliates to cross-border issues. Lofchie Comment: One of the many problems that Dodd-Frank creates is that it is far too prescriptive in what it requires; that is particularly a problem because some

The table below indicates the date, participants in and subjects of the meetings. & DATE MEETING WITH RULEMAKING 10/01/2012More Info Barclays Volcker 09/28/2012More Info SwapClear General 09/20/2012More Info SSgANatixisBNY MellonFidelity InvestmentsPatton Boggs Volcker