The Asset Management Group of SIFMA ("SIFMA AMG") submitted comments to the CFTC about the swap execution facility ("SEF") regulatory framework and related rules. The comment letter also responded to CFTC Commissioner Giancarlo's recent white paper on swaps trading rules. SIFMA AMG applauded Commissioner Giancarlo's "efforts to highlight certain adverse market consequences" of the current SEF regulatory framework. Specifically, SIFMA AMG expressed its support of Commissioner Giancarlo's suggestions, including the following: the made-available-to-trade ("MAT") process should be "significantly

FINRA announced that the National Adjudicatory Council ("NAC") revised its Sanction Guidelines regarding misrepresentations and suitability violations. The NAC amended the Sanction Guidelines to ensure that the overarching principles that apply to relevant determinations provide for tougher sanctions against those who commit fraud or make unsuitable recommendations to customers. The revised Sanction Guidelines now advise FINRA adjudicators to "strongly consider barring an individual respondent, or expelling a firm, for cases involving fraud." The guidelines recommend an increased range of one

Speaking at the Peterson Institute for International Economics in Washington, D.C., FDIC Chair Martin Gruenberg emphasized the "impressive and somewhat underappreciated" progress of the FDIC in implementing post-crisis regulatory reforms concerning the bankruptcy and resolution of systemically important financial institutions ("SIFIs"). First, Chair Gruenberg discussed efforts by the FDIC to strengthen the process for resolving SIFIs under the Bankruptcy Code, and noted that the FDIC has and will continue to provide guidance to SIFIs regarding the deficiencies in their Dodd-Frank resolutions

The CFTC's requested public comment on the proposed collection of certain information involving regulations that govern the bankruptcies of commodity brokers. The request was published in the Federal Register. The CFTC requests comments on the recordkeeping and notice requirements in CFTC Rule Part 190 that pertain to bankruptcy rules for commodity broker liquidations. Comments must be submitted by July 13, 2015. See: 80 FR 27152.

The CFTC released its final interpretation of "Forward Contracts with Embedded Volumetric Optionality" (the "Interpretation"). The Interpretation consists of seven elements that clarify when an agreement, contract or transaction falls within the forward contract exclusion from the "swap" and "future delivery" definitions in the CEA, notwithstanding that it contains embedded volumetric optionality. While most of the seven elements of the Interpretation remain largely unchanged from those in the original release, the fourth, fifth and seventh elements were modified for clarity. The seven