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The SEC has issued an order further extending the compliance date to November 1, 2013, with respect to the so-called Phase Two broker-dealer recordkeeping, reporting and monitoring requirements of the Large Trader Rule: Rule 13h-1 of the Exchange Act. The original compliance date for the broker-dealer recordkeeping, reporting and monitoring requirements of Rule 13h-1 was April 30, 2012. In granting additional time to comply with these requirements, the SEC adopted a two-phase approach. The first phase (Phase One), which had a November 30, 2012, compliance date, was limited to the provision by

In anticipation of U.S. Treasury Secretary Jacob Lew's upcoming visits with European finance officials, SIFMA submitted the attached comments to Secretary Lew raising a number of financial regulatory, tax and trade issues between the EU and U.S. In the letter, SIFMA highlights four main areas of concern, including: The extraterritorial nature of the European Union's and member states' Financial Transaction Tax programs; The divergence from Basel III in the EU's implementation of CRD IV related to the Credit Valuation Adjustments ("CVA"); The lack of progress by the EU on cross-border

Bob Zwirb Commentary by Bob Zwirb

ICI has filed a reply brief with the U.S. Court of Appeals for the District of Columbia Circuit in connection with its appeal of a federal district court's decision rejecting ICI's challenge to CFTC amendments to Rule 4.5 (which, among other things, provides certain exclusions from the definition of "commodity pool" and "commodity pool operator"). The CFTC amendments challenged by ICI had reinstated a trading threshold and marketing restriction for registered investment companies ("RICs") claiming an exclusion from the definition of "CPO" under Rule 4.5. (The CFTC had previously rescinded the

British Virgin Islands Premier Dr. D. Orlando Smith announced that, after careful analysis, the government of the British Virgin Islands ("BVI") has decided to pursue finalization of a Model 1B (Non-Reciprocal) Intergovernmental Agreement with the United States with respect to FATCA. In a speech made in the House of Assembly on April 4, Dr. Smith indicated that a similar agreement was being negotiated with the United Kingdom. "We have been in active discussions with the United States Treasury on this matter for some time now and will continue to move ahead to bring this matter to resolution as

Industry representatives met on February 19th to discuss with Gary Gensler, Jacqueline Mesa, and Steven Adamske issues regarding (i) segregation and bankruptcy, and (ii) cross-border. The following organizations were represented. Nomura, RBC, Deutsche Bank, Natisis Commodity Markets, Citigroup, BP, Newedge, Goldman Sachs, ICAP, ICE Futures Europe, CME Europe, Nasdaq OMX, LME, LCH Clearnet, UBS, Jefferies, BNP Paribas, Mizuho Securities USA, FOA, and the U.S. Embassy Click here to view CFTC Staff and all visitors and organizations present (links externally to CFTC website).