The SEC is proposing amendments to Rule 506 of Regulation D and Rule 144A under the Securities Act. These amendments are intended to implement Section 201(a) of the JOBS Act. The proposed amendment to Rule 506 would provide that the prohibition against general solicitation and general advertising contained in Rule 502(c) of Regulation D would not apply to offers and sales of securities made pursuant to Rule 506, provided that the issuer "take reasonable steps to verify" that all purchasers of the securities are accredited investors. The SEC did not, however, specify particular methods an

Commissioners Jill Sommers and Scott O'Malia submitted a joint statement to the CFTC regarding the notice of proposed rulemaking to exempt swaps between certain affiliated entities from the clearing requirement. Although the Commissioners believe it is appropriate that the Commission exempt inter-affiliate swaps from the clearing mandate, the Commissioners argue that the proposal inserts a requirement that most financial entities engaging in inter-affiliate swaps post variation margin to one another. Furthermore, the Commissioners state that it is not clear this requirement will do anything

ABA, et al.: ABA, The Clearing House, FSF, FSR, FIA, IIB, ISDA, ICI/ICI Global, MFA and SIFMA submitted a joint comment letter requesting that the CFTC extend the comment deadline on the cross-border proposed interpretive guidance and proposed exemptive order. Association for Financial Markets in Europe (AFME): AFME addressed whether the substituted compliance process is the most effective way to achieve the goals as set forth in Title VII of the Dodd-Frank Act. Association of German Banks: The Association stated its concerns that such regulatory efforts by the CFTC may lead to unnecessary

Lofchie Comment on Responses to the CFTC's ET Guidance: I had recently published a memo pointing out a variety of ways in which I believed the reach of Dodd-Frank (Title VII in particular) was either overbroad in its application to non-U.S. entities or discriminatory as to the treatment of non-U.S. entities in ways that I thought were not likely to be acceptable. Today, we publish in the news a summary of various comments as to the CFTC's proposed guidance on the reach of Dodd-Frank outside the United States. The comments from foreign governments are uniformly critical.When other responsible

FINRA is encouraging member firms with offices in the affected areas to prepare to implement business continuity plans in light of the tropical storm and hurricane warnings for coastal Louisiana, Mississippi, Alabama and the Florida Panhandle.