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SEC Acting Director of the Division of Trading and Markets John Ramsay delivered remarks at the NYC Bar Association on the Commission’s recent set of proposals on the cross-border regulation of derivatives. Equivalence vs. Substituted Compliance Director Ramsay discussed the status of international regulatory efforts, both in developing their derivatives regimes and in grappling with the cross-border regulation of derivatives trading. Two significant points that he made by way of introduction: (i) none of the other jurisdictions have proposed rules to describe how they would regulate cross

The attached document, prepared by the Delta Strategy Group, shows an estimated timeline for the implementation of the "SEF" requirements; i.e., (i) the ability for certain swap execution facilities ("SEFs") to register with the CFTC, (ii) the implementation of the requirement that certain swaps be traded on a SEF or on a fully regulated futures exchange and (iii) the process for determining the "block" size at which certain trading information would not be immediately publicly disseminated. Click here to see the draft timeline prepared by Delta Strategy Group.

The Ministry of Finance and the Inland Revenue Service of Singapore have announced that Singapore intends to conclude a Model 1 Intergovernmental Agreement ("IGA") on FATCA with the United States. In its statement, the Ministry indicated that this decision was based in part on feedback received from financial institutions located in Singapore that Model 1 offers stronger operational efficiencies and has a lower implementation cost. Singapore also announced that it was taking three other steps to improve its international exchange of information framework. First, Singapore will extend the

The Office of Inspector General ("OIG") conducted an in-depth review of the failure of Bank of Whitman ("Whitman") because the loss to the Deposit Insurance Fund presented unusual circumstances due to various questionable transactions and business practices involving senior management. According to the report, Whitman failed because of the convergence of several factors, which the executive summary outlined as follows: The bank altered its traditional agricultural lending strategy and expanded into new market areas, which resulted in rapid growth and high commercial real estate concentrations