This is a significant rulemaking for FCMs. Firms should carefully review the revised list of permitted investments and related conditions, including capital charges and concentration limits, and make required updates to policies and procedures, customer risk disclosure statements, and systems used for monitoring investment of customer funds and generating related reports.

This CFTC no-action letter preserves the status quo for the specified categories of nonbank SDs located in France and the UK while the CFTC completes its comparability determinations. SDs relying on the no-action relief should be mindful of the CFTC financial reporting and notice requirements of the relief.

FINRA continues to bring enforcement actions against broker-dealers for failure to include the "No Remuneration" indicator in TRACE reports, where required. In light of the regulatory focus on TRACE reports, firms should review their TRACE reporting systems and procedures to check that they are including required indicators. In this case, the firm failed to include the required no remuneration indicators on TRACE and MSRB reports for transactions with affiliates. 
 
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Here are some considerations on the increase in the Portfolio Requirement thresholds under CFTC :

(i) Investors who qualify as QEPs without having to meet the Portfolio Requirement. These include "qualified purchasers" and "knowledgeable employees" who are eligible to invest in funds falling within of the Investment Company Act. These investors…