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The SEC charged two business associates in Chile with insider trading on the nonpublic information that one of them learned while serving on the board of directors of a pharmaceutical company. The SEC alleged that one of the business associates exploited highly confidential information from CFR Pharmaceuticals S.A. board meetings at which a tender offer by Abbott Laboratories was discussed. The business associate caused the U.S. brokerage account, of which that business associate was the beneficiary, to purchase millions of dollars' worth of American Depositary Shares ("ADS") of CFR

Commentary by Nihal Patel

MFA submitted a letter to the SEC with updated comments and recommendations on the registration and regulation of security-based swap execution facilities ("SB SEFs"). This letter is intended to supplement MFA's comment letter dated April 4, 2011. MFA's supplemental comment letter offers recommendations based on MFA members' SEF trading experiences to date under the CFTC's SEF regime, which has been implemented in the years since the SEC first issued its proposed SB SEFs rules. In particular, the supplemental comment letter does the following: suggests completing a substantive review of the SB

ESMA published a preliminary cost-benefit analysis ("CBA") regarding regulatory technical standards and their implementation as proposed by ESMA for MiFID II. According to ESMA, the CBA should be read together with the Consultation Paper and the draft standards published by ESMA on December 19, 2014. Together, they cover most of the topics with which ESMA is mandated on Level 2. A full and all-encompassing CBA will follow, together with the publication of the final technical standards on MiFID II.

The Basel Committee on Banking Supervision ("BCBS") published a consultative paper titled "Revisions to the Standardized Approach for Credit Risk." According to the BCBS, the proposed revisions seek to strengthen the existing regulatory capital standards in several ways, including by: reducing reliance on external credit ratings; enhancing granularity and risk sensitivity; updating risk weight calibrations; increasing comparability with the internal ratings-based approach with respect to the definition and treatment of similar exposures; and improving clarity on the application of the

Commentary by Nihal Patel

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued a staff advisory for the chief compliance officers ("CCOs") of futures commission merchants, swap dealers and major swap participants ("Registrants"). The advisory provides guidance on the requirements to prepare an annual report on the state of the Registrants' compliance program under CFTC Rule 3.3(e). In connection with the advisory, DSIO also issued time-limited no-action relief to certain Registrants concerning the timing of the filing of the CCO annual report. CFTC Rule 3.3(f) requires the CCO annual report to be