In three separate comment letters, SIFMA, the Asset Management Group of SIFMA ("SIFMA AMG") and ISDA submitted comments to the CFTC on the proposed Position Limits for Derivatives and Aggregation of Position Limits rules ("Proposal"). SIFMA and ISDA submitted both a legal analysis of the Position Limits for Derivatives Proposal and comments, stating that they remain "deeply concerned" with many aspects of the Proposal and continue to challenge the fundamental premise on which the CFTC argues that it has authority to impose position limits under Dodd-Frank. The groups stated that they do not

The SEC announced that Division of Trading and Markets Acting Director John Ramsay will leave the SEC, and Stephen Luparello will be the new director. Additionally, the SEC named Sharon B. Binger as director of the Philadelphia Regional Office. Lofchie Comment: Both the outgoing and the incoming director have had long and distinguished careers in the securities industry. Mr. Luparello's joining the SEC at this time will add an important layer of expertise to this challenging and varied role. See: John Ramsay to Leave SEC; Stephen Luparello Named Director of Trading and Markets; Sharon Binger

The U.S. Department of the Treasury and Internal Revenue Service ("IRS") released the last substantial package of regulations necessary to implement the Foreign Account Tax Compliance Act ("FATCA"). The proposed and temporary regulations make additions and clarifications to previously issued FATCA regulations and provide guidance to coordinate FATCA rules with preexisting due diligence, reporting and withholding requirements under other provisions of the Internal Revenue Code ("Code").The new regulations include over 50 separate amendments and clarifications to the FATCA regulations issued in

Leaders of the North American Securities Administrators Association ("NASAA") from 18 states submitted a letter to SEC Chair White in response to the SEC's "attempt to preempt state authority over small corporate offerings" through its Proposed Rule Amendments and Additional Issues Exemptions under Securities Act Section 3(b) ("Regulation A+"). According to the letter, the NASAA leaders cannot fulfill their obligations to protect investors or help small businesses grow their companies when the SEC "attempts to prohibit our review as contemplated in the Regulation A+ Proposal." The letter

The SEC issued for comment a draft of its five-year Strategic Plan, which details its vision for the regulatory environment, resources, strategic goals and initiatives for the fiscal years 2014 through 2018. Lofchie Comment : It might be possible for the SEC to get through a material portion of this in the next five years if nothing new happens during that time. Click here to see a summary of the Strategic Plan from Delta Strategy Group. See also: SEC Strategic Plan.