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MFA, SIFMA and the Investment Company Institute (collectively, the "Associations") submitted a letter to SEC Chair Mary Jo White in advance of the SEC staff's recommendations for a rule proposal requiring the disclosure of customer-specific order-routing information upon institutional investors' request. Additionally, the Associations attached an order-routing disclosure template to the letter. The recommended disclosure template provides for the minimum disclosure of order-routing and execution-quality information that institutional investors could request from their broker-dealers. The

The Board of Governors of the Federal Reserve System ("FRB"), the Federal Deposit Insurance Corporation ("FDIC") and the Office of the Comptroller of the Currency ("OCC") released economic and financial market scenarios that financial institutions will be required to use as part of the 2015 Capital Planning and Stress Testing Program. Section 165(i)(2) of the Dodd-Frank Act requires certain financial companies, including national banks and federal savings associations with at least $10 billion in total consolidated assets, to conduct annual stress tests. The FRB, FDIC and OCC coordinated the

Bob Zwirb Commentary by Bob Zwirb

The CFTC's proposal to amend its Rules Part 14 ("Rules Relating to Suspension or Disbarment from Appearance and Practice") was published in the Federal Register. Under the proposed rule change, the CFTC may deny, temporarily or permanently, the privilege of certain persons to appear or practice before it. Additionally, the amendment clarifies the CFTC's standard for determining when an accountant has engaged in "unethical or improper professional conduct," which has been established as a basis for denying to such an accountant the privilege of appearing or practicing before the CFTC. Comments

The CFTC Division of Swap Dealer and Intermediary Oversight issued an interpretation of CFTC Rules 1.22, 22.2 and 30.7. The interpretation provides that a futures commission merchant ("FCM") may credit a customer's trading account for a margin payment upon the FCM's initiation of a withdrawal from the customer's bank account using the Automated Clearing House ("ACH") payment processing system. The interpretation is consistent with a previous staff interpretation of how an FCM should account for checks deposited by customers for margin payments. The interpretation also provides that an FCM may

Steven Lofchie Commentary by Steven Lofchie

The SEC, the Board of Governors of the Federal Reserve System ("FRB") and the Department of Housing and Urban Development ("HUD") voted to adopt the final Credit Risk Retention Rule. The rule was adopted on October 21, 2014 by the Federal Deposit Insurance Corporation ("FDIC"), the Office of the Comptroller of the Currency ("OCC") and the Federal Housing Finance Agency ("FHFA"), and implements Section 941 of the Dodd-Frank Act, which requires the securitizers of asset-backed securities to retain "not less than five percent" of the credit risk of assets collateralizing the securitization