Representative Barney Frank (co-author of the Dodd-Frank Act) submitted a letter to CFTC Chairman Gary Gensler and Treasury Secretary Timothy F. Geithner regarding the implementation of rulemakings that impact entities engaged in foreign exchange (FX) transactions. In particular, Representative Frank stressed the need for the Treasury to clarify what FX trades are to be considered "swaps" under Dodd-Frank, so that, among other things, firms can determine whether they will be required to register as swap dealers and major swap participants. Representative Frank expressly stated that he was not

NFA Financial Requirements Section 16 (effective September 1, 2012) requires FCMs to submit certain financial-related information to the NFA on a regular (monthly, semi-monthly or daily) basis. Financial Requirements Section 16 also requires FCMs that hold customer segregated and secured amount funds to report additional information, which may not be included in the firm's regular filings. The purpose of this notice is to provide instructions on how to file this additional information. The NFA further reminds FCMs that any information filed after its due date must be accompanied by a fee of $1

The Financial Services Authority (FSA) has fined and imposed a 5-year ban on former oil futures broker, Steven Noel Perkins, for market abuse on the grounds that he is not a fit and proper person, noting in paragraph 66 that "Mr Perkins poses an extreme risk to the market when drunk." Mr Perkins's actions under the influence were found to have created a temporary upward spike in the price of Brent Oil. View Final Notice here (links externally to FSA website). See also: FSA Press Release.

The MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee and the Board of IOSCO in response to the Basel-IOSCO Consultative Document on Margin Requirements for Non-Centrally-Cleared Derivatives. In the letter, the MFA urged the WGMR to take into consideration the importance of certain non-cleared derivatives as customized risk management tools, and set forth positions and recommendations on the following issues: Initial margin; Portfolio margining; Margin thresholds; IM schedule; and Ongoing review of requirements. View comment letter here

A recent study published in the FRBNY Economic Policy Review concludes that the collateral allocation and "unwind" processes are contributing to the market's fragility and inhibiting reform. The study report suggests that improving the collateral allocation process and eliminating the time gap between the "unwind" and "rewind" of repos could help reduce weaknesses in the market and limit systemic risk. Lofchie Comment: Tri-party repo has been one of the constant topics of discussion as a source of systemic risk. It was, for example, highlighted in FSOC's first annual report. View report here