John Sweeney, Branch 8 Chief, IRS Office of Associate Chief Counsel (International), said at a recent ABA Tax Section conference that a draft of the long-awaited FATCA registration form would be published "in the near future." The registration form will be used by foreign financial institutions (FFIs) to register as such with the IRS under the recently finalized FATCA regulations. Registration itself will be done using an online portal, but the registration form will detail the information required for determining the specific status of an entity as an FFI. Sweeney also said that a revised IRS
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The ABA Federal Regulation of Securities Committee submitted a comment letter to the SEC on crowdfunding. Because the SEC has not yet issued any proposed regulations concerning crowdfunding, the Drafting Committee took an expansive view of what the SEC might propose and offered 15 principal recommendations on the various issues potentially arising in connection with Title III (Crowdfunding) of the JOBS Act. Many of the recommendations are requests that the SEC "clarify" a point, "provide guidance," or "consider" an issue. Once regulations are actually proposed by the SEC, the Committee expects
The Bureau of Consumer Financial Protection (Bureau) is amending Regulation Z, which implements the Truth in Lending Act, and the Official Interpretations of the Regulation, which interpret the requirements of Regulation Z. Regulation Z generally limits the total amount of fees that a credit card issuer may require a consumer to pay with respect to an account to 25 percent of the credit limit in effect when the account is opened. Regulation Z previously stated that this limitation applies prior to an account opening and during the first year after an account opening. This final rule amends
SIFMA published a new white paper titled "Industry Recommendations for the Creation of a Consolidated Audit Trail (CAT)." The paper presents SIFMA's views on how the CAT system should be organized, provides key principles on operations, structure, governance and scope, and outlines the industry vision of how the CAT system should be implemented and expanded. SIFMA identified eight guiding principles for the development of a CAT system: Elimination of Duplicative Systems and Reporting; Appropriate Flexibility and Scalability; Centralized Administration; Public Transparency and Industry
The CFTC Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that provides certain futures commission merchants (FCMs) with limited relief as to the scope of the requirements of the annual report that the firm's chief compliance officer (CCO) must prepare and submit pursuant to CFTC Rule 3.3. The relief provided in the no-action letter would allow CCO to submit annual reports that did not satisfy all of the requirements of Rule 3.3(e) and (f); provided that the reports satisfied the conditions set forth in the no-action letter. The relief is available to all