The Office of Financial Research ("OFR") issued a brief in which OFR consultants Paul Glasserman and Bert Loudis examined a set of systemic importance indicators established by the Basel Committee on Banking Supervision. These indicators are intended to measure the threat to global financial stability that a large bank could pose if it were to fail. The Basel Committee's scoring methodology indicated that the largest U.S. banks rank relatively high in systemic importance based on measures of size, interconnectedness, complexity, cross-jurisdictional activity and the provision of services with

The Office of the Comptroller of the Currency ("OCC") issued a bulletin clarifying the extent to which national banks and federal branches may make or accept delivery of physical commodities to hedge commodity derivatives transactions. The bulletin also provides calculation guidance for determining whether physical hedging activities comprise a normal portion of risk management activities. Specifically, the bulletin (i) supplements BC-277, which outlines the OCC's supervisory expectations for the prudent risk management of financial derivatives, (ii) clarifies when a bank's physical commodity

The MSRB announced that new officers and members will join its Board of Directors and begin their terms on October 1, 2015. Nathaniel Singer will serve as the new Chair of the Board; Colleen Woodell, as the new Vice-Chair. Additional new members and public representatives of the board will include Ronald Dieckman, Megan Kilgore, Mark Kim and Andrew Sanford. See: MSRB Press Release.

In a speech at an interagency meeting on economic growth and paperwork reduction, FDIC Vice Chair Thomas Hoenig urged lawmakers to ease the regulatory burden on community banks. He stressed the importance of tailoring regulation to bank activities and complexity rather than their asset size. Mr. Hoenig recommended instituting an objective set of criteria for eligibility. Under these criteria, a bank would be eligible for regulatory relief if (i) it held no trading assets or liabilities; (ii) it held no derivative positions other than interest rate and foreign exchange derivatives; (iii) the

CFTC Commissioner J. Christopher Giancarlo revisited his own six-month-old white paper analyzing the CFTC's swaps trading regulatory framework. He provided a progress report on the issue. The Commissioner's white paper focused on eight areas including: (i) limitations on the permitted methods of execution, (ii) procedures regarding block transactions, (iii) the made-available-to-trade process, (iv) the void ab initio policy for swaps not accepted for clearing, (v) the process for providing confirmations of uncleared swaps, (vi) the embargo rule, (vii) the Core Principles to which swap