The CFTC announced that a public roundtable is scheduled for April 3, 2014, to discuss issues concerning end users. The roundtable will cover the following issues: the obligations of end users under CFTC Rule 1.35 ("Records of Commodity, Interest and Related Cash or Forward Transactions") concerning recordkeeping for commodity interest and related cash or forward transactions; the appropriate regulatory treatment of forward contracts with embedded volumetric optionality; and the appropriate regulatory treatment for purposes of the $25 million ("special entity") de minimis threshold for swap

The Office of Management and Budget ("OMB") announced that it is reviewing the CFTC's procedural requirements for requests involving interpretative, no-action and exemptive letters. Comments are due on April 7, 2014. See: 79 FR 12689.

The SEC issued a notice to extend the time period for SEC action, on the proposed rule change to amend FINRA's corporate financing rules, to simplify and refine the scope of the rules. The proposed rule change would amend FINRA Rule 5110("Corporate Financing Rule - Underwriting Terms and Arrangements") and Rule 5121("Public Offerings of Securities with Conflicts of Interest") to narrow the scope of certain definitions, modify the lock-up restrictions to exclude shares owned by an underwriter that are not considered "items of value," and limit certain information requirements to a

The SEC adopted revisions to the Electronic Data Gathering, Analysis and Retrieval System ("EDGAR") Filer Manual and related rules to reflect updates to the EDGAR system. The revisions primarily introduce new submission form types MA, MA-A, MA/A, MA-I, MA-I/A, and MA-W to support the registration of municipal advisors. Additionally, various other forms were updated. The system was updated on March 3, 2014. See: Text of Final Rule.

The SEC announced the largest-ever monetary sanction for violations of Regulation M Rule 105 ("Short Selling in Connection with a Public Offering"). The SEC found that the persons who were charged had engaged in a repeated practice of violations. They were required to pay $7.2 million to settle the charges. Lofchie Comment: It should be obvious by this point that the SEC's technology is quite good at catching violations of Rule 105. Apart from firms like the accused, which was seemingly engaged in systematic violations, other firms should be mindful that they have procedures in place to