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Bob Zwirb Steven Lofchie Commentary by Bob Zwirb and Steven Lofchie

The House and Senate voted to pass the Terrorism Risk Insurance Program Reauthorization Act of 2015 (H.R. 26), a bill that would, among other things, exclude end-users from CFTC and SEC margin requirements applicable to swaps. Specifically, the bill would amend the Commodity Exchange Act and Securities Exchange Act to exempt swaps from prudential rules governing margin requirements for swaps not cleared by a registered derivatives clearing organization. The bill calls for the amendment to be implemented through an interim final rule, bypassing the standard Administrative Procedure Act notice

The Financial Stability Oversight Council ("FSOC") requested public comments on a proposal to implement the qualified financial contract ("QFC") recordkeeping requirements of Dodd-Frank. The proposed rules provide information intended to assist the Federal Deposit Insurance Corporation ("FDIC"), acting as a receiver, to: fulfill its obligations under the Dodd-Frank Act in deciding whether to transfer QFCs; assess the consequences of decisions to transfer, disaffirm or repudiate, or to allow the termination of, QFCs with one or more counterparties; and determine if any financial systemic risks

The MSRB published its 2014 Annual Report, which reviews the organization's 2014 initiatives, as well as its financial highlights, and includes a link to the audited financial statements on the MSRB Web site. The report reviewed MSRB 2014 initiatives, including: the implementation of a comprehensive regulatory framework for municipal advisors, including the advancement of core rules of conduct and a professional qualification program; a focus on enhancing market structure, particularly in the areas of price transparency and fairness; recent and planned enhancements to the display of trade data