The SEC announced that Norm Champ, Director of the Division of Investment Management, will leave the agency later this month. Upon his departure from the SEC, Mr. Champ will become a Visiting Scholar for Spring Term 2015 at Harvard Law School, where he also is a lecturer on a biennial basis and teaches a course on investment management law. Lofchie Comment : With Director Champ's departure, the SEC will lose someone with significant experience and expertise, both in and out of government. Se e: Press Release.

Speaking before the Futures Industry Association in Japan, CFTC Chair Massad reiterated various cross-border initiatives that he had discussed in a previous speech in Hong Kong. Chair Massad identified the clearinghouse initiative as important, explaining that, as regulators require more firms to engage in clearing financial products, steps must be taken to ensure that clearinghouses do not pose a systemic risk. According to Chair Massad, regulators should not require all swaps to be cleared and, therefore, should set margin requirements for certain uncleared swaps. He stated that he is

In response to recent events involving the Swiss franc, the NFA announced that its Executive Committee will increase the minimum security deposits required to be collected and maintained by Forex dealer members ("FDMs") under NFA Financial Requirements Section 12. Section 12 requires FDMs to collect and maintain a minimum security deposit of two percent of the notional value of transactions in ten listed major foreign currencies, and five percent of the notional value of other transactions. Section 12 also permits NFA's Executive Committee to temporarily increase these requirements under

The FINRA proposal to extend the expiration date of FINRA Rule 0180 ("Application of Rules to Security-Based Swaps") to February 11, 2016 was published in the Federal Register. Generally, the extension has the effect of disapplying most of FINRA's rules to security-based swaps, even though such swaps are "securities" for purposes of the Securities Exchange Act. FINRA explained that it is "appropriate and in the public interest" to extend Rule 0180 in order to "avoid undue market disruptions resulting from the change of the definition of 'security'" under the Securities Exchange Act, at least

At the Bank of England in London, Federal Reserve Bank of New York Executive Vice President and General Counsel Thomas Baxter discussed the importance for financial services firms of developing and reinforcing an "ethical culture." Mr. Baxter stated that, although enforcement actions against bad actors and their employers can have a deterrent effect on undesirable behavior, enforcement actions are inevitably retrospective and must be complemented by combined efforts to build strong "ethical cultures" within financial institutions. To that end, Mr. Baxter recommended that financial services