The Division of Banking Supervision and Regulation of the Board of Governors of the Federal Reserve System ("FRB") issued a letter titled Principles and Practices for Recovery and Resolution Preparedness to clarify the heightened supervisory expectations for recovery and resolution preparedness for eight domestic bank holding companies that may pose elevated risk to U.S. financial stability. The letter states that the eight bank holding companies should have effective processes for the management, identification, and valuation of collateral received. Additionally, the letter sets out specific

The CFTC announced that the Technology Advisory Committee ("TAC") rescheduled its public meeting for February 10, 2014 at the CFTC's headquarters. At the meeting, the TAC, along with subcommittees on Automated and High Frequency Trading and Data Standards, will focus on issues related to swap data reporting, the CFTC's concept release on automated trading environments, and swap execution facilities ("SEFs"). The meeting was originally scheduled for January 21, but was postponed due to inclement weather. Lofchie Comment: As noted previously, the meeting would benefit from dissenting points of

The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") issued an exemptive letter for a commodity pool operator ("CPO") for three commodity pools formed on November 1, 2013, permitting the CPO to issue an annual report covering the entire fourteen months instead of a year. S ee: CFTC Letter 14-06.

The SEC published additions to its Securities Act Compliance and Disclosure Interpretations ("C&DIs"). The additions cover questions (see 260.28 to 260.34) regarding beneficial ownership in Rule 144 ("Persons Deemed Not to Be Engaged in a Distribution and Therefore Not Underwriter"). One of the principal interpretations, which is reinforced in several of the new additions, is that the term "beneficial owner" in Rule 506(d) should be interpreted by reference to the definition of that term in Exchange Act Rule 13d-3. (That term is discussed in detail in the "Ownership Chapter of the Guide to

The SEC published proposed amendments to Regulation A under Securities Act Section 3(b)(2) ("Classes of Securities under This Subchapter"), exempting securities offerings of up to $50 million from Securities Act registration requirements. The proposed amendments pertain to issuer eligibility requirements, as well as content and filing requirements for offering statements and ongoing reporting requirements for issuers. The rule changes are meant to implement Section 401 of the JOBS Act, which directed the SEC to provide an exemption for offerings of up to $50 million. Comments on the proposal