The Tax Section of the New York State Bar Association sent a 63-page report to the Treasury Department and IRS suggesting changes and clarifications that should be made to the final Foreign Financial Institution ("FFI") Agreement and to Intergovernmental Agreements ("IGAs") entered into between the United States and foreign countries. One of the thirty recommendations made by the Tax Section is that an FFI Agreement may only be terminated if there are multiple "material failures" by the FFI to meet its obligations under the Agreement, and that a Participating FFI should only be considered in

The SEC has published amendments in the Federal Register, to the Securities Exchange Act ("Exchange Act") and the Investment Company Act, which remove certain references to the credit ratings of nationally recognized statistical rating organizations ("NRSROs") in certain rules and forms. Specifically, the amendments apply to Exchange Act Rules 15c3-1 ("Net Capital Requirements for Brokers or Dealers") (and certain appendices), 15c3-3 ("Customer Protection - Reserves and Custody of Securities") and 10b-10 ("Confirmation of Transactions"), Investment Company Act Rule 5b-3 ("Acquisition of

IOSCO and the Financial Stability Board ("FSB"), each of which is an international coalition of national financial regulators, published a consultative document which proposes a high-level framework and specific methodologies for identifying non-bank non-insurer ("NBNI") global systemically important financial institutions ("SIFIs"). According to the FSB and IOSCO release, SIFIs are institutions whose distress or disorderly failure, because of their size, complexity and systemic interconnectedness, would cause significant disruption to economic activity and the wider financial system. At the

The Government Accountability Office ("GAO") issued testimony that was delivered by the Director of Financial Markets and Community Investment, Lawrance Evans, before the Senate Subcommittee on Financial Institutions and Consumer Protection. The testimony focused on a November 2013 GAO report that discussed issues related to government support for large bank holding companies. The federal government maintains programs, frequently referred to as "safety nets," to reduce the vulnerability of depository institutions that could threaten the health of the banking system and the broader economy

The MSRB published its 2013 Annual Report which, in very good summary form, describes its high-priority areas and activities, including regulatory efficiency, financial disclosure by state and local governments, municipal market transparency and the regulation of municipal advisors. The report also includes financial highlights for the organization for the fiscal year that ended September 30, 2013, and a link to access fully audited financial statements on the MSRB website. See: MSRB 2013 Annual Report. See also: MSRB Financial Statements for Fiscal Year Ending September 30, 2013.