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Steven Lofchie Commentary by Steven Lofchie

FDIC Vice Chair Thomas Hoenig argued the benefits of strengthening leverage capital requirements for derivatives. He compared two primary approaches for setting regulatory capital requirements: (i) leverage and (ii) risk-based standards. The Vice Chair criticized efforts to weaken the leverage ratio's treatment of derivatives, and declared that the alternative risk-based capital framework option has been "entirely unsuccessful." Vice Chair Hoenig delivered his remarks at the Exchequer Club of Washington D.C. In response to the argument "by some regulators" that the leverage ratio is a threat

IOSCO published a report in which it recommended sound practices for investment risk education. The report is intended to provide investors and regulators with information that will help to prevent the misalignment of perceived risk and actual investment risk. According to IOSCO, misalignment leads to "uninformed" decision-making and causes "significant financial loss and emotional harm" to investors.

The Investment Company Institute ("ICI") suggested revisions to the CFTC's proposed rule on the cross-border application of margin requirements for uncleared swaps.Specifically, ICI suggested that the proposed rule: include an exception to the definition of "U.S. person" for a pool, fund or other collective investment vehicle if it is publicly offered only to non-U.S. persons and not to U.S. persons; permit substituted compliance without qualification if the CFTC finds a foreign jurisdiction's margin requirements to be comparable to the margin rules; adopt a method for comparability

FINRA sanctioned ten former investment banking representatives from the same company in an ongoing effort to track groups of brokers who move from an expelled or high-risk firm to other securities firms. As a result of its 2014 onsite exam, FINRA found that the ten representatives engaged in securities fraud by using misleading sales pitches and high-pressure sales tactics in order to sell junk bonds and other securities to customers. Seven of the ten representatives had joined the firm together after leaving a previous company. FINRA's investigation found that the branch offices of both

The SEC delayed action on a proposed rule change to amend FINRA Rule 6730 ("Transaction Reporting"). A notice of the delay was published in the Federal Register. The FINRA-proposed amendment requires an indicator when the TRACE report does not reflect a commission or markup/markdown. SEC action is delayed until November 5, 2015.