The SEC Division of Investment Management issued a Guidance Update regarding the presentation of consolidated financial statements for certain investment companies registered under the Investment Company Act ("ICA") and investment companies that have elected to be treated as business development companies under the ICA that have wholly owned subsidiaries. See: SEC IM Guidance Update.
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Academic researchers from the University of Colorado and University of Chicago published a paper titled " Run EDGAR Run: SEC Dissemination in a High-Frequency World," which finds that the delay between an SEC filing's acceptance by the Electronic Data Gathering, Analysis, and Retrieval System ("EDGAR") and its initial public availability on the SEC website, may provide an advantage to certain traders that pay a subscription fee for direct access. According to the paper, while the delay is "relatively short," with a median posting time of 36 seconds, prices, volumes, and spreads respond to the
The CFTC Division of Swap Dealer and Intermediary Oversight issued an extension of previously issued time-limited, no-action relief to the Futures Industry Association, its member futures commission merchants ("FCMs"), and similarly situated FCMs regarding the simultaneous recording of book entry credits upon the receipt of customer funds via a wire transfer by an FCM. The relief extends previously issued no-action relief in Letter 14-88 pertaining to CFTC Rules 1.20 ("Futures Customer Funds to be Segregated and Separately Accounted For"), 22.2 ("Futures Commission Merchants: Treatment of
The CFTC Division of Swap Dealer and Intermediary Oversight issued an interpretation providing guidance as to the applicability of certain provisions of Commission Rules 23.701 ("Notification of Right to Segregation") and 23.704 ("Requirements for Non-Segregated Margin"). These regulations impose certain notification and reporting requirements on swap dealers ("SDs") and major swap participants ("MSPs") with involving margin posted by counterparties in uncleared swap transactions. Responding to several inquiries regarding the applicability of the regulations, the interpretation clarifies to
The Office of the Comptroller of the Currency ("OCC") revised its policy and procedures for handling Matters Requiring Attention ("MRA") that result from OCC examinations of supervised institutions. MRAs communicate specific supervisory concerns identified previously by the OCC during examinations, in writing, to boards and management teams of regulated institutions. An MRA must receive timely and effective corrective action by bank management and a follow-up by OCC examiners. The revised OCC guidance highlights changes to MRA policy and procedures that have been incorporated into the "Bank