The FINRA-proposed rule change regarding the implementation date for market participant identifier requirements for Alternative Trading Systems ("ATSs") was published in the Federal Register. FINRA proposed to postpone the implementation date to February 2, 2015, at which time ATSs will be required to use unique market participant identifiers when reporting order and trade information to FINRA. While the rule change was filed for immediate effectiveness, comments can be submitted until November 7, 2014. See: 79 FR 62500; FINRA Rule Filing. Related news: FINRA May Delay Implementation Date of

FINRA issued a Regulatory Notice regarding the SEC's approval of amendments to FINRA Customer and Industry Arbitration Codes to permit arbitrators to make a referral during an arbitration proceeding concerning a situation that the arbitrator has reason to believe poses a serious threat that is likely to harm investors unless immediate action is taken. The text of the amendments is set forth in Attachment A of the Regulatory Notice. The amendments are effective on October 27, 2014, for any arbitration case which has scheduled hearings remaining. See: FINRA Regulatory Notice 14-42; FINRA Notice

The Board of Governors of the Federal Reserve System ("FRB") issued a final rule to modify capital planning and stress testing regulations, and released instructions for the 2015 capital planning cycle. The final rule adjusts the due date for bank holding companies ("BHCs") with total consolidated assets of $50 billion or more to submit their capital plans and stress test results. For the 2015 capital plan cycle, such BHCs are required to submit capital plans on or before January 5, 2015, unchanged from prior years. For subsequent cycles, beginning in 2016, participating BHCs will be required

The Committee on Payments and Market Infrastructures ("CPMI") and IOSCO issued a report titled, "Recovery of Financial Market Infrastructures," which provides guidance to financial market infrastructures, such as central counterparties, on how to develop plans to enable them to recover from threats to their viability and financial strength. The report additionally provides guidance to relevant authorities in carrying out their responsibilities associated with the development and implementation of recovery plans. The report supplements the CPSS and IOSCO "Principles for Financial Market

The Tax Section of the American Bar Association ("ABA") submitted comments to the IRS and Treasury Department on proposed regulations issued on December 5, 2013 under Section 871(m) of the Internal Revenue Code. The comments advocate that such rules be modified to exclude certain transactions from coverage and to increase the "delta" threshold of 0.70 for imposing withholding on dividend equivalents on derivatives. Generally, Section 871(m) imposes withholding tax on certain actual or implicit payments on certain notional principal contracts and other equity-linked instruments that are