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ARTICLE · 04 APRIL 2017

Reg. Tracker: March 16 Through March 31

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The Cabinet Regulatory Tracker provides a list of upcoming effective dates, comment deadlines and compliance dates. Click on the links below to view deadlines that fall between March 16 and March 31, 2017.

United StatesFinance and Banking

The Cabinet Regulatory Tracker provides a list of upcoming effective dates, comment deadlines and compliance dates. Click on the links below to view deadlines that fall between March 16 and March 31, 2017.

For continuous real-time updates, please consult the Cadwalader Cabinet Regulatory Calendar.

Effective Dates

  • March 20: FINRA amendments to the FINRA Rule 6700 Series and the Trade Reporting and Compliance Engine dissemination protocols.
  • March 27: Board of Governors of the Federal Reserve System ("FRB") final rule that applies an inflation adjustment to the $10 billion total consolidated asset threshold.
  • March 27: FRB final rule requiring a U.S. top-tier bank holding company identified under the FRB rules as a global systemically important bank holding company to maintain outstanding a minimum amount of loss-absorbing instruments, among other measures.

Comment Deadlines

  • March 16: CFTC proposal that would establish minimum capital, liquidity, financial reporting and other related requirements applicable to CFTC-registered swap dealers and major swap participants.
  • March 17: DOL and Employee Benefits Security Administration ("EBSA") proposal that would add a 60-day extension to (i) the applicability date defining who is a "fiduciary" under the Employee Retirement Income Security Act and the Internal Revenue Code, and (ii) the applicability date of related prohibited transaction exemptions.
  • March 20: CFTC proposal that would amend certain recordkeeping obligations.
  • March 24: CFTC-proposed technical amendments to regulations that govern the registration and review of exchange disciplinary, access denial or other adverse actions.
  • March 24: SEC-proposed pay ratio disclosure rule in response to unanticipated compliance difficulties reported by issuers.
  • March 24: MSRB-proposed new advertising requirements.
  • March 27: FINRA proposal that would create an exception to the general prohibition on providing performance projections.
  • March 27: CFTC proposal that would amend swap data, registration and disciplinary review requirements.
  • March 31: FINRA report that examines the implications of distributed ledger technology (or "blockchain technology") on the securities industry.

Compliance Dates

  • March 20: CFTC-enhanced requirements for testing by a derivatives clearing organization of its system safeguards.
  • March 23: FINRA Monthly and Fifth FOCUS Part II/IIA filing deadline for the period ending on February 28, 2017.
  • March 28: FINRA Supplemental Inventory Schedule Form filing deadline for the month ending on February 28, 2017.

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