The table below indicates the date, participants in and subjects of the meetings. & Lofchie Comment: Among the meetings noted below was one in which various non-U.S. government regulators came in as a group on September 25 to meet with the CFTC. Many of these governments submitted comment letters that were extremely critical of the CFTC's extraterritorial jurisdiction. Presumably, the fact that they met jointly with the CFTC indicates that they have reached a consensus on their reaction. Canada had not submitted a letter to the CFTC, so it is notable that Canada joined the group. DATE MEETING

SIFMA has published comments to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision (BCBS) and IOSCO on the Consultative Document on margin requirements for non-centrally-cleared derivatives. This letter includes a proposed universal two-way initial margin requirement aimed at ensuring that interconnected intermediaries have sufficient resources to withstand a major counterparty default without transmitting the resulting losses to third parties. SIFMA further recommends suggestions regarding: Segregation of initial margin; Cross-margining and

A recent study published in the FRBNY Economic Policy Review concludes that the collateral allocation and "unwind" processes are contributing to the market's fragility and inhibiting reform. The study report suggests that improving the collateral allocation process and eliminating the time gap between the "unwind" and "rewind" of repos could help reduce weaknesses in the market and limit systemic risk. Lofchie Comment: Tri-party repo has been one of the constant topics of discussion as a source of systemic risk. It was, for example, highlighted in FSOC's first annual report. View report here

The MSRB announced that it has seated seven new members of its Board of Directors and installed new officers for the fiscal year that begins October 1. The 21-member Board establishes regulatory policies and oversees the operations of the MSRB. Eleven members represent the public; ten represent entities regulated by the MSRB. View press release in full here (links externally to MSRB website).

Representative Barney Frank (co-author of the Dodd-Frank Act) submitted a letter to CFTC Chairman Gary Gensler and Treasury Secretary Timothy F. Geithner regarding the implementation of rulemakings that impact entities engaged in foreign exchange (FX) transactions. In particular, Representative Frank stressed the need for the Treasury to clarify what FX trades are to be considered "swaps" under Dodd-Frank, so that, among other things, firms can determine whether they will be required to register as swap dealers and major swap participants. Representative Frank expressly stated that he was not