SIFMA submitted comments to the U.S. Department of Treasury and the IRS requesting transitional relief from FATCA. SIFMA stated that it understands the challenges that the Treasury and IRS faced in developing the Temporary and Proposed Regulations published on March 6, 2014 ("2014 Regulations"), which substantially revised the obligations of financial institutions with respect to FATCA, as well as Chapters 3 and 61 in Section 3406 of the Internal Revenue Code (the "Harmonization Rules"). However, SIFMA stated, the consensus of its members is that it will not be possible for the global

SIFMA submitted comments to SEC on the rule change proposed by the Options Clearing Corporation ("OCC") to reflect the elimination of a discount to OCC's clearing fee schedule. While recognizing that the OCC (as a systemically important financial markets utility) needs to raise capital to comply with new proposed SEC requirements, SIFMA urged the OCC to provide additional clarity on the reasoning behind its plan to change its price schedule before the new schedule takes effect. Se e: SIFMA Comment Letter.

SIFMA submitted comments to the SEC regarding FINRA's proposed rule change to adopt Rule 2243, Disclosure and Reporting Obligations Related to Recruitment Practices (the "Proposal"). In the letter, SIFMA expressed support for the underlying goal of the Proposal: to foster investor protection by requiring broker-dealers to disclose (in concise, plain English) certain potential conflicts of interest that may arise in connection with a registered representative's receipt of recruiting-related bonus payments. Notwithstanding the general support for the concept, SIFMA contended that various

The United States Government Accountability Office ("GAO") released a report assessing the SEC's information security controls as part of its audit of the SEC's financial statements from fiscal years 2013 and 2012. The report noted that, while the SEC had implemented and made progress in strengthening information security controls, weaknesses limited their effectiveness in protecting the confidentiality, integrity and availability of a key financial system. The report noted further that the information security weaknesses existed because the SEC did not sufficiently oversee and manage the

The Securities Industry and Financial Markets Association ("SIFMA"), the American Bankers Association ("ABA"), the Financial Services Forum ("FSF"), the Financial Services Roundtable ("FSR") and the Institute of International Bankers ("IIB") (collectively referred to as the "Associations") submitted a comment letter to the Board of Governors of the Federal Reserve System ("FRB") on complementary activities, merchant banking activities and other activities of financial holding companies ("FHCs") related to physical commodities. In the letter, the Associations stated that the public benefits of