The NFA reminded members that April 1, 2019 is the effective date for amendments to the Interpretive Notice relating to information systems security programs ("ISSP"). As previously covered, the amendments concern cybersecurity training obligations, the approval of a firm's ISSP, and cybersecurity breach notifications.

In connection with the Share Class Selection Disclosure Initiative ("SCSDI"), the SEC settled charges against 79 investment advisers, who will collectively return over $125 million to clients. The majority of the funds will go to retail investors. The SEC Orders found that the investment advisers placed clients in higher-cost mutual fund share classes that charged ICA Rule 12b-1 fees ("12b-1 fees") when a lower-cost share class was available without adequately disclosing that the higher-cost class was being selected. According to the Orders, the 12b-1 fees were paid to the investment advisers

In its March 8, 2019 Financial Institution Letter, the Federal Financial Institutions Examination Council ("FFIEC") finalized revisions to the Consolidated Reports of Condition and Income ("Call Report"), as well as to certain other reports, in accordance with changes in the accounting for credit losses pursuant to the Financial Accounting Standards Board's Accounting Standards Update 2016-13. Highlights of the revisions include changes to the Call Report and the FFIEC 101 report to implement the banking agencies' recent revisions to the regulatory capital rules and reporting changes. These

ISDA CEO Scott O'Malia commended the Basel Committee on Banking Supervision and IOSCO ("BCBS-IOSCO") statement on the implementation of derivatives margin requirements and urged additional action. As previously covered, the BCBS-IOSCO statement addressed the implementation of derivatives margin requirements as they relate to (i) benchmark reforms and (ii) initial margin thresholds. Mr. O'Malia commended the BCBS-IOSCO statement for addressing the potential application of documentation and other requirements where parties fall below the EUR 50 million threshold in the BCBS-IOSCO margin

The Financial Information Forum ("FIF") offered recommendations to streamline the Regulation ATS-N submission process. The process requires broker-dealers to publicly post Form ATS-N filings on the SEC's website. In a comment letter to the SEC, FIF recommended: permitting alternative trading systems ("ATSs") to submit disclosure information in formats other than narrative form when applicable ( e.g., in tables, charts and bullets); allowing ATSs to "cut and paste from internal documents," which would mitigate possible transcription mistakes; incorporating a "comment" field in Form ATS-N to