SIFMA and the American Securitization Forum (ASF) submitted the comments to the CFTC requesting relief to address "legacy" structured finance transactions. The groups stated that there are factors that distinguish these financings from those done on a prospective basis, which would therefore lessen the CFTC's regulatory interests and justify regulatory relief on a broader basis. A draft exemptive order was submitted for purposes of discussion (included in the letter). The structures to which the relief would apply are as below: "Legacy Entity" means an entity, regardless of its legal form

The MSRB has revised the study outline for the Municipal Securities Principal Qualification Examination (Series 53). The Series is designed to determine whether an individual meets the MSRB's qualification standards for a municipal securities principal. The revisions remove rescinded rules and include amendments and additions to the MSRB's rules. Series 53 examinations based on the revised study outline will commence on December 22, 2012. View Study Outline in full here (links externally to MSRB website). See also: MSRB Notice.

The IOSCO has published a final report on Global Developments in Securitization Regulation, which proposes a series of recommendations aimed at ensuring securitization markets, including cross-border markets, develop on what IOSCO views as a sound and sustainable basis. In addition to making recommendations, the report provides a very broad overview of the state of the securitization markets around the world. (It is fairly remarkable how substantially these markets have shrunk in size.) The primary recommendations, which start on page 48, relate to risk retention and standardization of

The Federal Reserve Board released the economic and financial market scenarios for the next round of stress tests for large financial institutions. View press release in full here (links externally to Federal Reserve website).

William Dudley, president of the Federal Reserve Bank of New York, gave a speech at the Clearing House's Annual Business Meeting titled "Solving the Too Big to Fail Problem". Dudley stated the problem in two parts: (i) whether society should tolerate a financial system in which certain financial institutions are deemed to be too big to fail, and (ii) if not, what we should do about it. To the first question, Dudley stated that the answer is "clearly" that "we cannot tolerate a financial system in which some firms are too big to fail--at least not ones that operate in any form other than that