Several sources have reported that the U.S. Treasury may not decide whether to exempt certain currency derivatives from new rules until late November, at best. The failure to specify which FX trades are "swaps" materially adds to the level of uncertainty for all parties attempting to determine whether they will be required to register as swap dealers or major swap participants and which regulations will apply to currency trades, bearing in mind that the definition of "swap" is due to become effective this October. Lofchie Comment: There is a direct thematic relationship between the absence of

MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the regulation of electronic trading. In the letter, MFA supports the requirement that intermediaries implement pre- and post-trade risk controls. The primary focus of MFA's letter is as to which types of entities should be subject to which burdens. In regulating electronic trading, MFA believes that there should be an important distinction between an intermediary/vendor that provides electronic connectivity services (i.e., connectivity and routing access to liquidity centers) and end-users

Arkansas Securities Commissioner and NASAA President A. Heath Abshure made a statement on the current status of implementation of the JOBS Act including rulemakings under Titles II (General Solicitation and Advertising in Rules 506/144A), III (Crowdfunding) and IV (Regulation A+) of the Act. Commissioner Abshure stated that implementation of legislation designed to foster the flow of capital to small businesses must be done responsibly and carefully. While Commissioner Abshure conceded that rules implementing the JOBS Act were long overdue, he pointed out that rules implementing Dodd-Frank are

The Alternative Investment Management Association (AIMA) has announced the appointment of a new non-Executive Chairman, Kathleen Casey, the former SEC Commissioner and representative to the International Organization of Securities Commissions (IOSCO) and the Financial Stability Board (FSB). The period of her appointment is for two years. She replaces outgoing AIMA non-Executive Chairman Todd Groome following the expiry of his term.

The Futures and Options Association has issued guidance aimed at providing listed derivative market participants with industry standards to mitigate the risk of transacting in electronic trading environments, in particular with regards to high-frequency and automated trading. The guidance looks to complement and build on the European Securities and Markets Authority guidelines on systems and controls in an automated trading environment, which came into force in May. Key objectives of the guidance include clarifying the duties and responsibilities of market participants. Lofchie Comment: The