In a new paper (the "Paper"), ISDA and several foreign banking and securities dealers associations (collectively, the "associations") analyzed the potential adverse effects of a "no deal" Brexit scenario on OTC derivatives business under EU law; that is, in a situation in which (i) the UK withdraws from the EU without an agreement with the EU and (ii) there is no transition period for market participants. In the Paper, the associations stated that a "no deal" scenario would create a "disruptive 'cliff edge' change" in EU regulatory requirements regarding OTC derivatives business. A "no deal"

The SEC updated its Compliance and Disclosure Interpretations (C&DIs) to remind issuers that the revised disclosure requirements as to shareholders' equity go into effect on November 5, 2018. SEC staff stated that it would not object to changes in shareholders' equity made by the filer if the changes are included in Form 10-Q for the first quarter that begins after the effective date of the amendments (see Question 105.09).

At its September Board meeting, FINRA approved significant revisions to margin requirements for Covered Agency TBA (to-be-announced) Transactions. The revisions would, pending approval by the SEC: (i) eliminate the 2 percent maintenance margin requirement and (ii) allow firms to take capital charges in lieu of collecting margin, within certain limits. In addition, FINRA approved the publication of a Regulatory Notice to seek comments on amendments to Rule 4210 to "clarify and incorporate . . . current interpretations" regarding "when-issued" and extended settlement transactions. In other

The SEC approved an amendment to FINRA’s Trade Reporting and Compliance Engine (TRACE) rules. The change will require certain alternative trading systems ("ATSs") to report to FINRA and the U.S. Treasury Department ("Treasury") (but not to the public) the identities of non-FINRA member subscribers that are parties to Treasury securities transactions. The new reporting requirement comes into effect on April 1, 2019. As previously covered, the reporting requirement would apply only to ATSs that have executed Treasury securities transactions with non-FINRA members in an amount equal to at least

The Global Foreign Exchange Committee ("GFXC") launched a survey to measure the awareness and adherence to the FX Global Code (the "Code"). The survey is intended to help the GFXC in determining effective mechanisms for encouraging compliance with the Code. The GFXC will consider the survey results at its next meeting, which will take place from November 29 to November 30, 2018. In addition, the GFXC provided updates on current initiatives: The "Cover and Deal" trading activity working group is drafting a summary highlighting how the Code may apply its good practice recommendations in the