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SIFMA submitted the attached comment letter to the Financial Crimes Enforcement Network of the U.S. Department of Treasury ("FinCEN") on the imposition of special measures against Halawi Exchange Co., Kassem Rmeiti Co. for Exchange, and Liberty Reserve S.A., as financial institutions of primary money-laundering concern.In the letter, SIFMA declared its support for FinCEN's efforts to detect and prevent money-laundering and the financing of terrorist activity, whether through the identified financial institutions or otherwise, and requested clarifications and modifications with respect to the

SIFMA submitted comments to the SEC regarding a National Securities Clearing Corporation ("NSCC") proposal to institute supplemental liquidity deposits to NSCC's clearing fund ( see SR-NSCC-2013-02 and SR-NSCC-2013-802 ). This "SLD Proposal" is designed to increase liquidity resources to meet NSCC's liquidity needs. SIFMA voiced concern over particular parts of the proposal due to its complexity and potentially far-reaching implications. SIFMA anticipates that this will affect not only business and capital models of a broad range of market participants, but also the broader financial system

The ISDA announced the publication of Additional Provisions relating to Credit Derivative Transactions with a Restricted Delivery Party where Physical Settlement applies. The Additional Provisions are for use where the settlement method is physical settlement and one of the two conditions applies: Either party to the Credit Derivative Transaction is restricted from holding a Loan; or There is a limit on the outstanding principal balance of a Bond which it may hold. See: ISDA News Release.

Bob Zwirb Commentary by Bob Zwirb

Better Markets, Inc., on the one side, and a coalition involving the Edison Electric Institute, the Electric Power Supply Association and the CME Group, on the other, have filed opposing amicus briefs with the D.C. Court of Appeals in CFTC's appeal of a federal district court decision vacating its position limits rules issued under Dodd-Frank, ISDA v. CFTC, 887 F. Supp. 2d 259 (D.D.C. September 28, 2012). The Better Markets brief, which focuses on the cost-benefit requirement of CEA Section 15, argues that, although Section 15 requires the CFTC to "consider" the costs and benefits of proposed