The CFTC issued an exemptive letter to a CPO regarding CFTC Rule 4.22, which requires that a firm file a certified Annual Report to the NFA within 90 days of the Pool's fiscal year. The CFTC stated that the principal purpose of the reporting required by CFTC Rule 4.22 is to ensure that pool participants receive accurate, fair and timely information on the overall trading performance and financial condition of the pool. The CFTC reasoned that since the CPO is the controlling principal and managing member of the CPO and also the sole participant in the Pool, the CPO is not required to issue a

In an article titled "The Intrafirm Complexity of Systemically Important Financial Institutions," Center for Financial Stability ("CFS") senior fellow and American University Professor Robin Lumsdaine and her co-authors propose a framework for assessing the organizational complexity of individual financial institutions via network-based metrics. Professor Lumsdaine states that to date, the designation of systemically important financial institutions ("SIFIs") is the result of an evaluation of the size of an institution combined with an assessment of its level of interconnectedness with other

In a letter to House Agriculture Committee Chairman Mike Conaway (R-TX), CFTC Chairman Timothy Massad criticized the "Commodity End-User Relief Act" (H.R. 2289). The bill would reauthorize the CFTC for five years. Chairman Massad stated that many of the provisions outlining the CFTC's regulatory powers are unneeded or unduly restrictive, and "would make it harder to fulfill our mission." The Bill is similar to legislation passed by the House during the last Congress. It would codify and clarify Congressional intent where certain customer protections are concerned, reform the CFTC's operations

SEC Director of the Division of Enforcement (the "Division") Andrew Ceresney discussed the importance and success of the SEC's cooperation program. He delivered his remarks at the University of Texas School of Law. Mr. Ceresney explained that the SEC's formal cooperation program was launched five years ago to provide for the use of formal cooperation agreements, as well as other tools. The SEC also identified four general considerations for assessing cooperation: (i) assistance provided by the cooperator, (ii) importance of the underlying matter, (iii) interest in holding the individual

The SEC charged Nationwide Life Insurance Company ("Nationwide") with violating pricing rules routinely in its daily processing of purchase and redemption orders for variable insurance contracts and underlying mutual funds. An SEC investigation found that in spite of receiving customer orders and other variable contract mail in its P.O. boxes at least several hours before the 4:00 p.m. cut-off time, Nationwide sought to dodge its requirement to use the current day's price to process the orders by ensuring that this mail wasn't delivered to its offices until after 4:00 p.m. The SEC's order