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On April 24, the IRS revised the FATCA FAQs on its website to add several new questions and answers dealing with qualified intermediaries, expanded affiliated groups and other interpretative questions. An entire new section titled "General Compliance" contains five new questions and answers. For example, one of the questions addressed is this: How do Certified Deemed-Compliant Foreign Financial Institutions ("FFIs"), Owner-Documented FFIs and Excepted FFIs certify to withholding agents that they are not subject to FATCA withholding, given that they are not required to register with the IRS and

The North American Securities Administrators Association ("NASAA") released a report indicating a wide disparity in how broker-dealers disclose fees, as well as questionable practices regarding broker-dealer fee charges and "markups." (The "markups" in question are not on securities transactions, but rather on fees for services, such as providing a stock certificate, where the fee charged by the broker-dealer is significantly in excess of the out-of-pocket cost of furnishing the service.) The report stated that, while broker-dealers may be complying with the technical requirements governing

On April 15, the European Parliament adopted a Directive that will require large companies to include in their annual statements a non-financial disclosure concerning their approach to certain social matters, including anti-bribery issues. Assuming the Directive becomes law, which appears likely, companies will be required to describe their policies, risks and results with respect to anti-bribery, human rights, the environment and diversity on boards of directors, among other issues. The law does not require companies to make a "fully-fledged and detailed report," but rather necessitates the

The Managed Funds Association ("MFA") submitted a comment letter to the CFTC expressing its strong support for the CFTC's interim final rule issued in Swap Data Repositories - Access to SDR Data by Market Participants (the "Amended SDR Access Rule"). MFA commended the CFTC's revisions, which are intended to protect counterparty anonymity with respect to all swaps that are first traded anonymously on designated contract markets and swap execution facilities and then cleared in accordance with the Commission's straight-through-processing requirements. MFA noted that, in amending CFTC Rule 49.17