SIFMA criticized FINRA's proposed Rule 3260 ("Discretionary Accounts and Transactions") (the "Proposal"). The Proposal addresses the treatment of customers' free credit balances and sweep programs, the bulk transfers of customers' accounts and changes of the broker-dealer of record. SIFMA's criticisms of the Proposal included the following: The signature requirement for authorized persons under Proposed Rule 3260(b) raises significant operational, cost, regulatory and other concerns with no investor protection benefit. The Proposal's update requirement will result in a significant
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A broad coalition of industry groups urged regulators to exclude client collateral when calculating the total assets of banks, and argued that an unchanged leverage ratio would "reduce access to clearing and undermine one of the main goals of financial reform."
Deputy Comptroller for Compliance Operations and Policy, Grovetta Gardineer asserted that the OCC has taken steps to supervise and enforce better treatment of members of the armed forces under the Servicemembers Civil Relief Act of 2003 ("SCRA") and under amended rules implementing the Military Lending Act ("MLA"). In a speech delivered before the Association of Military Banks of America, Ms. Gardineer discussed OCC directives to banks to improve SCRA-compliance policies and procedures. She also discussed the expanded coverage of MLA rules under recent Department of Defense final amendments
The NFA proposed the adoption of an Interpretive Notice to NFA Compliance Rules 2-9, 2-376 and 2-49. The notice would require member firms to "adopt and enforce written procedures to secure customer data and access" to their electronic Information Systems Security Programs ("ISSPs") pursuant to Section 17(j) of the Commodity Exchange Act. The NFA stated that, prior to drafting the notice, it had "reviewed guidance issued by other financial regulators" on cybersecurity, including FINRA's February 2015 Report on Cybersecurity Practices, the SEC's April 2015 Guidance Update and SIFMA's July 2014
The FDIC released a Statement of Policy outlining principles for the development and distribution of stress test scenarios to assess the potential impact of economic conditions on covered banks' earnings, losses, and capital. Stress tests help both banks and the FDIC ensure sufficient capital to absorb losses under adverse economic conditions, with scenarios based on baseline, adverse, and severely adverse financial conditions. The FDIC collaborates with other regulatory bodies to develop these scenarios, which are distributed annually to covered banks by November 15th.