The SEC has proposed rules intended to increase access to capital for smaller companies pursuant to the JOBS Act. The proposed rules would update the Regulation A "Conditional Small Issues Exemption," which currently provides an exemption from registration for small offerings of securities up to $5 million within a 12-month period. The updated exemption would expand Reg. A by creating two tiers of Reg. A offerings: Tier 1, which would consist of those offerings already covered by Reg. A - namely, securities offerings of up to $5 million in a 12-month period, including up to $1.5 million for
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The National Futures Association ("NFA") has issued a notice to its members regarding how the Christmas holiday will impact regulatory filings. The NFA stated that the regulatory filing schedule is as follows: Daily segregated, 30.7 secured, cleared swaps customer collateral and daily forex statements prepared as of December 24, 2013 are required to be submitted by 12:00 noon on December 26, 2013; Daily segregated statements are not required to be prepared as of December 25, 2013; Daily 30.7 secured, cleared swaps customer collateral and forex statements are required to be prepared as of
The Government of Malta announced that it has entered into a Model 1A (Reciprocal) Intergovernmental Agreement ("IGA") with the United States. Under the terms of the IGA, each country agrees to collect and turn over to the other country its information on accounts maintained within its borders by residents of that other country. In connection with signing the IGA, Malta announced that it would soon be announcing a voluntary disclosure plan for residents of Malta to file and pay taxes that have not previously been reported before disclosure begins under the IGA. The text of the IGA has not yet
The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued a no-action relief to two futures commission merchants ("FCMs") from the oral recordkeeping requirements of CFTC Rule 1.35(a)(1) ("Records of Commodity, Interest and Related Cash or Forward Transactions"). CFTC Rule 1.35(a)(1) requires FCMs to record all oral communications "provided or received concerning quotes, solicitations, bids, offers, instructions, trading, and prices that lead to the execution of a transaction in a commodity interest." In response to comments asserting that the cost of implementing and
The Office of the Comptroller of the Currency ("OCC") and Financial Institutions Examination Council ("FFIEC") published final supervisory guidance titled "Social Media: Consumer Compliance Risk Management Guidance." "Social media" is broadly defined to include "interactive onlne communication," and services such as LinkedIn, Google Plus, Facebook and Twitter. The OCC stated that technological advancements allow financial institutions to use social media in a variety of ways, including marketing; facilitating applications for new accounts, products, or services; and engaging with existing and