The OCC, Federal Reserve and FDIC (collectively, the "agencies") are seeking comment on three notices of proposed rulemaking (the "NPR") that propose to revise and replace the agencies' regulatory capital rules. While these NPRs were originally issued in June and slated to be open for public comment until September 7, the agencies have now extended the comment period to October 22. The first NPR describes the agencies' proposal to revise their risk-based and leverage capital requirements consistent with Basel III; the second contains proposals to revise and harmonize rules for calculating risk

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In response to SEC Chairman Mary Schapiro's proposal to restructure money market funds, Commissioner Daniel M. Gallagher and Troy A. Paredes submitted a joint statement on the reasons for their disagreement with the Chairman's proposal. Specifically, they asserted that the proposals were not supported by sufficient data, would be expensive to the economy and would create risk in the economy. The Commissioners recommended that the SEC staff conduct more detailed research and analysis on money market funds before the SEC proposed rules. This statement follows Commissioner Aguilar's statement

Commissioners Jill Sommers and Scott O'Malia submitted a joint statement to the CFTC regarding the notice of proposed rulemaking to exempt swaps between certain affiliated entities from the clearing requirement. Although the Commissioners believe it is appropriate that the Commission exempt inter-affiliate swaps from the clearing mandate, the Commissioners argue that the proposal inserts a requirement that most financial entities engaging in inter-affiliate swaps post variation margin to one another. Furthermore, the Commissioners state that it is not clear this requirement will do anything

FIA and ISDA announced the publication of the FIA-ISDA Cleared Derivatives Addendum, a template that can be used by U.S. FCMs and their customers to document their relationship with respect to OTC swaps. The Addendum includes representations for each party to make regarding certain clearing-related matters, such as the treatment of customer collateral. It also sets forth the close-out methodology for cleared OTC swaps, the triggers for liquidation and provisions for valuing the terminated trades. Lofchie Comment: Any client seeking information as to the specific provisions of the Addendum, and