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ISDA announced the launch of the ISDA 2013 Account Control Agreement ("ISDA ACA"). The ISDA ACA is intended to streamline tri-party custodial negotiations by facilitating the negotiation process of contractual arrangements that provide for segregation of Independent Amounts with a third-party custodian. Similar to the ISDA Master Agreement, the ISDA ACA agreement provides a standardized agreement with an accompanying annex containing suggested optional provisions that can be appropriately amended. See: ISDA Press Release.

The National Futures Association ("NFA") released a Notice to members indicating that all futures commission merchants ("FCMs") and forex dealer members ("FDMs") are required to do an initial one-time filing of management personnel information by November 30, 2013, pursuant to the recent amendments to NFA Compliance Rule 2-38("Business Continuity and Disaster Recovery Plan"). Following Hurricane Sandy, Compliance Rule 2-38 was amended to expand its business continuity and disaster recovery reporting requirements. Each FCM and FDM must file contact information for all key management personnel

SEC Associate Director of Enforcement Steven L. Cohen delivered a speech at the SCCE Annual Conference in which he focused on the importance of strong compliance programs at firms and steps that the SEC is taking to support robust compliance programs. Mr. Cohen emphasized the significant role that compliance programs play in a post-Dodd-Frank world. He stated that compliance professionals are at the "epicenter" of daily business decisions that could pose a significant risk to companies and financial markets. Mr. Cohen explained that one of his greatest concerns regarding compliance is that

SIFMA President Ken Bentsen testified today before the Senate Banking, Housing and Urban Affairs Committee on the potential impact of a U.S. debt default on financial stability and economic growth. In his testimony, Mr. Bentsen called on the Congress and the Administration to come together to "put our fiscal house in order." He stated that U.S. debt obligations are the currency of the global financial market and their soundness should not be questioned. He asserted that a short-term failure to fulfill America's financial obligations would impair market operations. He noted that markets have