The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued no-action relief to a commodity pool operator ("CPO") regarding the Annual Report filing and certification requirements in CFTC Rules 4.22(c) and (d) ("Reporting to Pool Participants"). Additionally, the DSIO granted exemptive relief from CFTC Rule 4.22(d)(1) on the condition that the CPO file an uncertified Annual Report for the 2013 fiscal year, in full compliance with CFTC Rule 4.22(c), by May 31, 2014. See: CFTC Letter 14-61.

CBS Corp. recently announced that the IRS will permit CBS Outdoor Americas Inc. ("Outdoor") to convert to a real estate investment trust ("REIT"), which will receive more favorable tax treatment. Earlier this month, Outdoor completed an IPO, distributing 19% of its stock, and CBS plans to distribute its remaining Outdoor stock to CBS shareholders in a tax-free split-off later this year. Nugent Comment: A company generally can qualify as a REIT, which normally is taxed only at the shareholder level, if its business is based primarily on real estate holdings and it distributes at least 90% of

The SEC issued an Order granting a waiver to the Royal Bank of Scotland Group, Plc ("RBS") from being considered an ineligible issuer, pursuant to the definition of "ineligible issuer" in Securities Act Rule 405. RBS submitted a letter on March 27, 2014 that constituted an application for the waiver, due to the entry on January 14, 2014, of a judgment against RBS Securities Japan Limited, which found RBS Japan guilty of felony wire fraud. Paragraph 2 of the definition of "ineligible issuer" in Rule 405 states that an issuer shall not be an ineligible issuer if the SEC determines, upon showing

The SEC Division of Corporation Finance issued a letter confirming that the designation of each of NASDAQ OMC Stockholm AB, NASDAQ OMX Copenhagen A/S and NASDAQ OMX Helsinki Ltd. (the "Exchanges") as a "designated off-shore securities market" under Regulation S includes "First North," a division of each of the Exchanges that focuses on the trading of small and midsized companies. See: SEC Letter to the Exchanges; Incoming Request from Exchanges to SEC.

In a Joint Statement issued on April 28, SEC Commissioners Gallagher and Piwowar assert that the United States District Court for the District of Columbia should invalidate the SEC's conflict minerals rule in its entirety. The Commissioners also argue that the SEC should grant a full stay of the conflict minerals rule pending the District Court's ruling. The Commissioners offer two reasons for the ultimate rejection of the rule. First, they argue that the courts would eventually invalidate the entire rule, given their belief that First Amendment concerns "permeate all the required disclosures