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SIFMA released a statement in response to Senator Richard Burr's (R-NC) offering of the Cybersecurity Information Sharing Act ("CISA") as an amendment to the National Defense Authorization Act ("NDAA"). SIFMA commended Senator Burr for introducing the CISA as an amendment to the NDAA, and strongly encouraged the Senate to adopt the amendment. According to SIFMA, information sharing legislation, such as that put forward by Senator Burr, "will empower businesses and government agencies with the best information to protect consumers and stay ahead of the rapidly evolving and increasingly

IOSCO published its final report outlining eight good practices for reducing overreliance on external credit rating agencies ("CRAs") in the asset management industry. In the report, IOSCO explained that the use of CRAs is driven primarily by demand, and stated that references to external credit ratings may derive from regulatory requirements or an investor's internal rules. IOSCO cautioned that the use of CRAs could result in "mechanistic reliance," and speculated that CRAs could trigger forced asset sales in the event of downgrades. IOSCO outlined eight recommendations that investors can use

In its letter to the IRS, the Investment Company Institute ("ICI") requested guidance regarding the tax treatment of contributions from a stable net asset value ("NAV") fund to a floating NAV fund. The ICI stated that in order to comply with the SEC's money market fund rules, investment advisers may decide to make cash contributions to existing money market funds to bring the shadow NAV of a fund up to $1.0000. The ICI explained that while, for book purposes, the contribution would not result in gain or income to the fund, and largely would be treated as paid-in capital, the tax treatment of

The National Futures Association ("NFA") fined FX Evolve and its principal (together, "FX Evolve") for failing to observe high standards of commercial honor and failing to supervise. The NFA found that FX Evolve violated NFA Compliance Rule 2-36(c) when it knowingly conducted business with firms and individuals that were not registered with the NFA and facilitated unauthorized trades between individuals who had previously pleaded guilty to bank fraud, conspiracy and income tax evasion. The NFA also found that FX Evolve violated NFA Compliance Rule 2-9(c) when the firm (i) failed to provide AML

Commentary by Nihal Patel

The European Supervisory Authorities ("ESAs") published a second consultation paper on the draft Regulatory Technical Standards ("RTS"). The document outlines the framework for the margin requirement for non-centrally cleared derivatives under EMIR. The second consultation paper builds on the proposed outlined in the ESAs' first Consultation Paper, published in April 2014. After reviewing the responses to the first consultation paper, the ESAs engaged in dialogue with other authorities to identify operational issues that may arise from the implementation of the EMIR framework. The ESAs are