The Division of Swap Dealer and Intermediary Oversight issued a no-action letter providing time-limited, and otherwise limited, no-action relief from the obligation to include any forex swap or forex forward for purposes of determining a person's registration requirement as an SD, MSP or CPO. Be aware that the relief is quite limited. It applies for purposes of the calculations relevant to determining if a person is a major swap participant or SD, but significant aspects of the relief are only available if the Treasury determines (which is uncertain at this point) to exempt such swaps or
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The Division of Swap Dealer and Intermediary Oversight ("DSIO") issued the attached no-action letter regarding the treatment of agricultural and exempt commodities in making calculations for purposes of the swap dealer and major swap participant definitions. The no-action letter states that the DSIO will not recommend the CFTC take action against any person for: failure to include, in its calculation of the aggregate gross notional amount of swaps connected with its swap-dealing activity for purposes of CFTC Rule 1.3(ggg)(4), a swap that (i) references an exempt commodity or agricultural
The CFPB released an informal guidance regarding the pending remittance transfer requirements. Section of 1073 of the Dodd-Frank Act expanded the scope of the Electronic Fund Transfer Act's requirements for certain international fund transfers - transactions referred to as "remittance transfers." The Dodd-Frank Act required the CFPB to issue rules to implement Section 1073's provisions regarding certain disclosures, and cancellation and error resolution procedures. These regulations were published February 7, 2012 (along with model forms and official staff commentary), and additional safe
The SEC is proposing to extend the effectiveness of Rule 206(3)-3T under the Advisers Act, a temporary rule that establishes an alternative means for investment advisers that are registered with the SEC as broker-dealers to meet the requirements of Section 206(3) of the Advisers Act when they act in a principal capacity in transactions with certain of their advisory clients. The amendment would extend the date on which Rule 206(3)-3T will sunset from December 31, 2012 to December 31, 2014. During that extended period, the SEC intends to study, among other things, the standard of care
The Dodd-Frank Act requires the Federal Reserve Board to conduct annual stress tests of bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies that the Financial Stability Oversight Council (Council) designates for supervision by the Board (nonbank covered companies, and together, with bank holding companies with total consolidated assets of $50 billion or more, covered companies) and also requires the Board to issue regulations that require covered companies to conduct stress tests semi-annually. The Board is adopting this final rule to