At the CME Global Financial Leadership Conference, CFTC Chair Massad spoke about cross-border challenges and various regulatory reform initiatives at the CFTC. After first addressing the CFTC's mandate under Dodd-Frank generally, and outlining certain of his "core principles," Chair Massad highlighted the "cross-border challenge" faced by the CFTC. In particular, Chair Massad focused on clearing and clearinghouse oversight across borders. Chair Massad explained that he believes that the proper model for clearinghouses would require dual registration and cooperative oversight among regulators

In a speech before the ALI CLE 2014 Conference on Life Insurance Company Products, SEC Division of Investment Management (the "Division") Director Norm Champ discussed a number of issues being addressed currently by the Division, paying particular attention to variable products and the use of derivatives by mutual funds. Mr. Champ began by discussing market changes in the variable products space. In particular, he indicated concerns over the suitability and disclosure of new features in variable annuities and the use of derivatives to hedge risks associated with living benefits. More generally

The Government Accountability Office ("GAO") issued a report detailing the results of its audits of the financial statements of the SEC and its Investor Protection Fund ("IPF") for fiscal years 2013 and 2014. The report found, among other things, that: the SEC and IPF's financial statements were presented fairly and in accordance with U.S. generally accepted accounting principles; the SEC maintained effective internal control over financial reporting for the SEC and IPF as of September 30, 2014; and the GAO found no reportable noncompliance in fiscal year 2014 with provisions of applicable

FINRA issued a Regulatory Notice requesting comments on two proposals intended to increase transparency in the equity markets. The first proposal would amend the Order Audit Trail System ("OATS") rules to require member firms to identify nonmember broker-dealers when reporting orders received from such entities. FINRA says that such disclosures would, among other things, allow it to (i) "more readily detect potentially violative trading activity" by such nonmembers and (ii) more effectively determine whether members are complying with regulatory obligations, including Exchange Act Rule 15c3-5

FINRA and the MSRB issued separate Regulatory Notices requesting comments on companion rule proposals that would require firms to disclose additional information on customer confirmations for transactions in fixed income securities. Although the proposals are similar, FINRA and the MSRB seek input on factors that are unique to the corporate and municipal bond markets, respectively. Although they differ in terms of details, the proposals have similar broad policy aims. Both proposals would require firms to disclose, in confirmations for "retail-size" transactions with customers, the price of