FINRA extended the effective date of the margin requirements for Covered Agency Transactions, including "to-be-announced" ("TBA") transactions and other forward-settling agency securities transactions. The effective date was extended from March 25, 2019 to March 25, 2020. FINRA reminded members that the "risk limit determination requirements became effective on December 15, 2016 and are not affected by this Notice."

The Office of the Comptroller of the Currency ("OCC") proposed amending the OCC's company-run stress testing requirements for national banks and federal savings associations. The proposal is consistent with section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act. Comments on the proposal must be submitted by March 14, 2019. The proposal would, among other things: increase the minimum threshold for national banks and federal savings associations to conduct stress tests from $10 billion to $250 billion; reduce the frequency with which certain banks would be obligated to

The CFTC Division of Swap Dealer and Intermediary Oversight (the "Division") granted no-action relief to three CPOs from registration and the requirement to deliver quarterly account statements. The Division granted relief ( see here and here) to two CPOs from registration, provided that each CPO delegated its responsibilities under CEA Section 4m(1) to a registered CPO, subject to certain conditions. The relief was granted notwithstanding the parties' inability to meet one of the conditions - that the "Delegating CPO" and the "Designated CPO" be under common legal control - so long as they

FINRA staff provided interpretive guidance on FINRA Rule 2210, which imposes certain requirements on institutional communications. In an interpretive letter, FINRA staff stated that it does not object to the use of pre-inception index performance ("PIP") data in institutional communications concerning registered open-end investment companies. FINRA staff clarified that the interpretive letter does not impact its "long standing position that the presentation of hypothetical back-tested performance in communications used with retail investors does not comply with the content standards contained

A broker-dealer agreed to settle NASDAQ Stock Market LLC ("Nasdaq") charges of failing to "maintain a continuous two-sided trading interest . . . at prices within certain percentages away from the [National Best Bid or Offer]." According to the Letter of Acceptance, Waiver and Consent, OTA LLC ("OTA") allegedly failed to meet its market maker-quoting obligations because it failed to "continuously quote in the security" due to an internal system error that shut down quoting. Nasdaq found that while OTA's written supervisory procedures identified a designated supervisor responsible for carrying