In 2014, the CFTC issued CFTC Letter 14-111 permitting Fannie Mae and Fredie Mac to rely on CFTC Rule 4.13(a)(3), the de minimis exemption from CPO registration, in connection with credit risk transfer ("CRT") structures that transferred mortgage credit risk from Fannie Mae and Freddie Mac to institutional investors via an SPV. CFTC Letter 25-37 provides similar relief to regulated financial institutions in connection with qualifying CRT structures that transfer financial exposures held on…

This action highlights the importance of (i) accurate programming of data feeds used to generate research disclosures, and (ii) ongoing supervision of those data feeds to ensure the accuracy of those disclosures. Failure to catch errors early may result in repeat violations and significant fines. 

Separately, FINRA sanctioned the firm for transactions by a research analyst in "third-party managed accounts" which were inconsistent with the analyst’s stock rating. FINRA Rule 2241…

This is a significant rulemaking for FCMs. Firms should carefully review the revised list of permitted investments and related conditions, including capital charges and concentration limits, and make required updates to policies and procedures, customer risk disclosure statements, and systems used for monitoring investment of customer funds and generating related reports.

This CFTC no-action letter preserves the status quo for the specified categories of nonbank SDs located in France and the UK while the CFTC completes its comparability determinations. SDs relying on the no-action relief should be mindful of the CFTC financial reporting and notice requirements of the relief.