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Scott Cammarn Commentary by Scott Cammarn

On December 14, 2012, the Board of Governors of the Federal Reserve System (FRB) proposed regulations under Section 165 and Section 166 of the Dodd-Frank Act to increase the oversight of U.S. operations of foreign banking organizations (FBOs) – foreign banks that maintain a U.S. branch or agency office. The proposed regulations follow on the heels of FRB Governor Daniel K. Tarullo’s speech on November 28, 2012, announcing the FRB’s intent to adopt such regulations. In proposing the regulations, the FRB cites the increasing complexity of FBOs in the United States and the attendant risks that

The SEC announced that a federal judge in Boston, Massachusetts entered a final judgment against registered investment adviser EagleEye Asset Management, LLC, and its sole principal, Jeffrey A. Liskov in an action the Commission previously filed against them. The Commission’s action alleged that that the defendants defrauded advisory clients concerning foreign currency exchange (“forex”) trading. The Commission alleged that, as a result of this conduct, EagleEye and Liskov violated Section 10(b) [Manipulative and deceptive devices] of the Exchange Act and Rule 10b-5 [Employment of manipulative

The Committee on Payment and Settlement Systems (CPSS) and the International Organization of Securities Commissions (IOSCO) have published a disclosure framework and assessment methodology for their Principles for Financial Market Infrastructures (PFMIs), the new international standards for FMIs. The disclosure framework is intended to promote consistent and comprehensive public disclosure by FMIs in line with the requirements of the PFMIs, and the assessment methodology provides guidance for monitoring and assessing observance with the PFMIs. Both the framework and methodology facilitate

FINRA is filing with the SEC a proposed rule change to amend NASD Rule 1022 (Categories of Principal Registration) and NASD Rule 1032 (Categories of Representative Registration) to extend the deadline by which eligible registrants must complete a firm-element continuing education requirement to engage in a security futures business. The extension is to December 31, 2015, or one business day prior to the date a revised examination that includes security futures products is offered. The filing suggests that there may not be enough security futures business to justify FINRA revising its exams to

CFTC Commissioners Bart Chilton and Jill E. Sommers (Chair of the Global Markets Advisory Committee) delivered testimony on the status of Dodd-Frank before the U.S. House of Representatives Committee on Agriculture Subcommittee. Commissioner Sommers shared her view on the challenges facing regulators across the globe in trying to meet the commitments on over-the-counter (OTC) derivatives reform made by G20 Leaders in 2009 as well as the challenges presented in interpreting the cross-border scope of Dodd-Frank. In particular, Sommers highlighted five areas which need further exploration