MFA submitted comments to the Basel Committee on Banking Supervision ("BCBS") regarding the treatment of segregated initial margin under the supplementary leverage ratio ("SLR") set out in the BCBS document titled: " Basel III Leverage Ratio Framework and Disclosure Requirements." MFA stated that it is "very concerned" that the SLR does not account for the fact that segregated customer initial margin for centrally cleared derivatives cannot be used to leverage the customer's clearing member firm. According to MFA, customers post initial margin to their clearing firms for the benefits of

FINRA filed a proposed rule change with the SEC to extend the expiration date of FINRA Rule 0180 ("Application of Rules to Security-Based Swaps") to February 11, 2016. Generally, the extension has the effect of disapplying most of FINRA's rules to security-based swaps, even though such transactions are "securities" for purposes of the Securities Exchange Act. Regarding the extension of its July 2011 order granting temporary exemptive relief, FINRA explained that it is "appropriate and in the public interest" to extend Rule 0180 so as to "avoid undue market disruptions resulting from the change

The Committee on Rules for the U.S. House of Representatives announced that it would convene on January 12, 2015 to consider two proposals for regulatory reform: (i) H.R. 37, the Promoting Job Creation and Reducing Small Business Burdens Act (the "Economy Act"); and (ii) H.R. 185, the Regulatory Accountability Act of 2015 (the "Accountability Act"). The Economy Act was first considered by the U.S. House of Representatives on January 7 but failed to secure the necessary two-thirds vote required for passage under House rules applicable at the time. The Economy Act is being re-proposed under

An MFA blog post provides a discussion of the new reporting requirements that are applicable under the European Union's Alternative Investment Fund Managers Directive. See: MFA Blog Post.

FINRA released a podcast summarizing the latest notices, compliance resources and news from December 2014. FINRA reminded members of their filing obligations for annual audit and FOCUS Form Custody and Supplemental FOCUS Reports, and of the reports' due dates throughout 2015 and in the first quarter of 2016. FINRA also reminded firms of their obligations to disclose the material risks to customers of extended-hours trading, as described in Regulatory Notice 14-54. FINRA reminded members of an e-mail by Chairman and CEO Rick Ketchum, in which he reviewed rule-making proposals that were approved