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Commentary by Conor Almquist

Three broker-dealers agreed to settle SEC charges for failing to submit complete and accurate securities trading information on electronic blue sheets. According to the three SEC Orders ( see here, here and here), the firms each made inadequate blue sheet submissions containing inaccurate data. The SEC alleged that the broker-dealers had insufficient processes to detect the accuracy of its submissions. The SEC took into account remedial acts and cooperation by the three broker-dealers. To settle the charges, the firms agreed to pay fines ranging from $1.4 million to $3.5 million.

The Federal Reserve Board and Consumer Financial Protection Bureau (collectively, the "agencies") proposed amendments (the "2018 proposal") to Regulation CC, which implements the Expedited Funds Availability Act ("EFA Act"). The agencies also reopened the comment period on proposed amendments to the funds availability provisions of Regulation CC and related definitions and appendices (the "2011 proposal"). In the 2018 proposal, the agencies proposed a calculation methodology for implementing a statutory requirement to adjust the dollar amounts in the EFA Act every five years. Comments on the

The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") extended the expiration date of certain General Licenses concerning companies on the Specially Designated Nationals and Blocked Persons list. Specifically, the General Licenses 13H, 14D, 15C and 16D modified their previous versions by extending the expiration date from January 7, 2019 to January 21, 2019. General License 13H, which replaces General License 13G, authorizes certain transactions necessary to divest or transfer debt, equity or other holdings in EN+ Group PLC, GAZ Group and United Company RUSAL PLC

The CFTC proposal to amend Rule 160.5 - which requires certain "covered persons" ( i.e., FCMs, RFEDs, CTAs, CPOs, IBs, MSPs and SDs) to provide annual privacy notices to customers at least once a year during the life of the customer relationship - was published in the Federal Register. Comments must be submitted by February 8, 2019. As previously covered, the proposed revisions implement the Fixing America's Surface Transportation Act's (FAST Act) December 2015 statutory amendment to the Gramm-Leach-Bliley Act.