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The Federal Reserve Board, the Office of the Comptroller of the Currency ("OCC"), the FDIC and the National Credit Union Administration updated its FAQ on the new credit losses accounting standard. Separately, the OCC rescinded two Bulletins related to the new credit losses accounting standard. As previously covered, the new accounting standard introduces the current expected credit losses methodology ("CECL") for "estimating allowances for credit losses." The amended FAQ adds to the guidance provided in 2017 and 2016, specifically addressing: collateral-dependent loans; "reasonable and

A broker-dealer agreed to settle FINRA charges for Order Audit Trail System ("OATS") reporting and Regulation NMS violations. According to the Letter of Acceptance, Waiver and Consent, the firm: failed to include an information barrier identifier in relevant OATS reports to indicate that the firm relied on information barriers to comply with restrictions on trading ahead of relevant customer orders; failed to submit certain execution reports to OATS; and improperly routed an "intermarket sweep order to a covered exchange priced outside of a least one protected quotation without simultaneously

In an Investor Alert, FINRA and the SEC Office of Investor Education and Advocacy cautioned investors on the risks associated with "social sentiment investing tools" ( i.e., tools analyzing or aggregating data from social media sources to inform investment decisions). The alert provides tips for investors prior to using such tools.

Steven Lofchie Commentary by Steven Lofchie

The SEC Division of Corporation Finance granted no-action relief to an airline chartering business incorporated in Delaware from the registration requirement relating to offering and selling "tokenized" jet cards. The SEC relied on the company's representations that the subject "tokens" are not securities. The SEC's relief was also subject to numerous additional representations. In particular, the SEC noted that: the platform on which the tokens would be used had already been constructed, thus, revenues from the sale of the tokens were not being used to build the necessary technology; the