Australian Securities and Investments Commission, et al.: The Australian Securities and Investments Commission, Hong Kong Monetary Authority, Monetary Authority of Singapore, Reserve Bank of Australia and Securities and Futures Commission, Hong Kong, submitted a joint comment letter to CFTC Chairman Gary Gensler. The organizations discussed their concern that the CFTC Proposed Guidance (subjecting non-U.S. persons to the swap dealer or major swap participant registration requirements, as well as entity-level and transaction-level requirements) would have the following consequences: Affected

CFA Institute: CFA Institute suggested that the Commission accommodate the interim registration of non-U.S. firms as Swap Dealers and Major Swap Participants as they wait for the implementation of comparable regulation in their home markets. In addition, the Institute believes that the Commission should avoid shortcuts in the due diligence needed to implement the Proposal in order to meet their deadlines. U.S. Chamber of Commerce: Commerce discussed setting an appropriate scope for the Dodd-Frank extraterritorial application, which is crucial for achieving effective cross-border swaps

MFA submitted a comment letter to the Division of CFTC for interpretive relief for a commodity pool operator (CPO) exempt from registration under the CFTC's Section 4.13(a)(3) de minimis trading exemption transitioning to full registration status. MFA urged the CFTC to consider issuing interpretive guidance providing that a CPO that has filed an exemptive notice under Section 4.13(a)(3) may continue to operate the fund, taking positions that exceed the de minimis level, provided that the operator submits a notice to the CFTC of its intention to register and uses its best efforts to become

Bank of America Corporation, et al.: Bank of America Corporation, Citigroup Inc., and JPMorgan Chase Co. submitted a modified comment letter addressing several compelling issues which they believe are highly relevant to the cross-border application of Dodd-Frank. Bank of America, et al.: Bank of America Merrill Lynch, Barclays Capital, PNB Paribas, Citi, Credit Agricole Corporate and Investment Bank, Credit Suisse (USA), Deutsche Bank AG, HSBC, Morgan Stanley, Standard Chartered Bank, UBS AG, and Wells Fargo Company submitted a joint comment letter to the CFTC outlining several concerns about

FINRA is encouraging member firms with offices in the affected areas to prepare to implement business continuity plans in light of the tropical storm and hurricane warnings for coastal Louisiana, Mississippi, Alabama and the Florida Panhandle.