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The National Futures Association ("NFA") Board of Directors ("the Board") filed a proposed rule change with the CFTC to amend NFA's Articles of Incorporation to increase CPO/CTA representation on its Board. Currently, the Board must include four CPO/CTA representatives, of which at least two must rank in the top 20 percent of funds under management allocated to futures and swaps. The amendment would increase the number of CPO/CTA representatives to five on the Board and require that at least three of these rank within the top 20 percent of funds under management and one rank within the top

FINRA issued a trade reporting notice reminding reporting firms of their obligation to report cancellations of OTC trades reported to a FINRA facility. This obligation applies to all trades reported for publication purposes that ultimately do not clear and settle. This includes, for example, trades that have been declined by the contra party. See: FINRA Notice; FINRA Executive Summary.

Bob Zwirb Commentary by Bob Zwirb

The European Securities and Markets Authority ("ESMA") published two separate consultation papers seeking comment on draft regulatory technical standards ("RTS") for the clearing of Interest Rate Swaps ("IRS") and Credit Default Swaps ("CDS") under the European Market Infrastructure Regulation ("EMIR"). The papers provide explanations on the draft regulatory technical standards establishing a clearing obligation on certain interest rate and OTC derivative classes. They also seek input from stakeholders to help ESMA in finalizing technical standards to be drafted and submitted to the European

The CFTC issued a comment request relating to a petition submitted by ICE Clear Europe Limited ("ICE Clear Europe") for an order regarding CEA Section 4d(a) ("Dealing by unregistered futures commission merchants or introducing brokers prohibited; duties in handling customer receipts; rules to avoid duplicative regulations"). The petition requests that the CFTC amend an earlier order dated May 30, 2014. The May 30, 2014 order permitted ICE Clear Europe and its clearing members that are registered futures commission merchants ("FCMs") to: Commingle in an account subject to Section 4d(a) (a

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued time-limited no-action relief to futures commission merchants ("FCMs") regarding the CFTC requirement that FCMs obtain an acknowledgement letter from certain depositories that hold customer funds. The relief is necessary to provide additional time to finalize the depositories' access agreements with the CFTC, until October 17, 2014. In the letter, the DSIO provided additional time for FCMs to comply with CFTC Rules 1.20(d)(3)(i) and (ii) ("Futures Customer Funds to be Segregated and Separately Accounted For"), 1.26 (