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The Consumer Financial Protection Bureau ("CFPB") stated that it expects to issue proposed rules in January 2019 aimed at (i) amending the Payday, Vehicle Title, and Certain High-Cost Installment Loans rule and (ii) delaying the rule's compliance date. The CFPB clarified that it is currently planning to revisit only the ability-to-repay provisions and not the payments provisions.

Steven Lofchie Commentary by Steven Lofchie and Nihal Patel

CFTC Commissioner Rostin Behnam advocated for international regulatory cooperation to address the risks posed by benchmark reforms, margin, Brexit, cross-border regulation and FinTech. In a speech at the 2018 ISDA Annual Japan Conference, Mr. Behnam weighed in on the following: Benchmark Reforms. Mr. Behnam emphasized the importance for global regulatory authorities to work with one another as well as private sector entities to facilitate the transition away from various inter-bank offer rates. He praised the work being done by, among others, the UK FCA, Japanese regulators, and, in the United

Market structure experts at the MSRB provided their analysis of pre-trade quote data for municipal securities traded on two alternative trading systems ("ATSs"). The report focused on price discovery and usefulness of ATS quotes as pre-trade information by looking at request-for-quotes ("RFQ") data and live offer data from two ATS platforms. The key findings of the report include: almost 70 percent of the trades reported to the MSRB had a live offer quote on at least one of the two ATSs during the time of a trade execution; over 90 percent of the quoted municipal bonds had one or two offer

In anticipation of Brexit, the UK Government prepared various statutory orders to ensure that the current legal framework for the derivatives market and ring-fencing regime remains effective.