The Cabinet Regulatory Tracker provides a list of significant upcoming comment deadlines, effective dates and compliance deadlines. Click on the links below to view deadlines that fall between September 1 and September 15, 2016.

For continuous real-time updates, please refer to the Cadwalader Cabinet Calendar.

Comment Deadlines

  • September 16: MSRB proposal to delay by two years, until August 29, 2018, the date on which submissions must be made pursuant to Rule G-45, on reporting of information on municipal fund securities, by underwriters of programs established to implement the Able Act.
  • September 19: FERC proposal to revise its regulations to collect certain data for analytics and surveillance purposes from market-based rate ("MBR") sellers and entities trading virtual products or holding financial transmission rights and to change certain aspects of the substance and format of information submitted for MBR purposes.
  • September 20: CFTC proposal to amend certain of its regulations applicable to the Annual Report that each person registered or required to be registered as a commodity pool operator must distribute for each commodity pool that it operates.
  • September 23: FINRA proposal to amend FINRA Rules 3220, 3221 and 3222 concerning gifts, gratuities and non-cash compensation.
  • September 26: FERC proposal to incorporate by reference the latest version (Version 003.1) of certain Standards for Business Practices and Communication Protocols for Public Utilities adopted by the Wholesale Electric Quadrant of the North American Energy Standards Board.
  • September 26: Petitions for candidacy for nomination process to fill one Mid-size Firm vacancy and one Large Firm vacancy on the National Adjudicatory Council.
  • September 26: SEC proposal to amend Rules 600 and 606 of Regulation National Market System under the Securities Exchange Act to require additional disclosures by broker-dealers to customers about the routing of their orders.
  • September 29: CFTC proposal to amend its regulations to enhance the process for reviewing whistleblower claims and to make related changes to clarify staff authority to administer the whistleblower program.
  • September 30: IOSCO consultation report reviewing liquidity issues in the secondary corporate bond markets.

Effective Dates

  • September 21: FERC elimination of the exemptions for wind generators from the requirement to provide reactive power by revising the pro forma Large Generator Interconnection Agreement, Appendix G to the pro forma LGIA, and the pro forma Small Generator Interconnection Agreement.
  • September 23: Board of Governors of the Federal Reserve System revisions to part II of the Federal Reserve Policy on Payment System Risk related to the procedures for measuring balances intraday in institutions' accounts at the Federal Reserve Banks to conform with enhancements to the Reserve Banks' same-day automated clearinghouse service previously approved by the Board.
  • September 26: SEC final Rule 13q-1 and final amendment to Form SD to implement Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the disclosure of payments by resource extraction issuers.
  • September 27: FERC new or modified Reliability Standard intended to mitigate the risk of a cybersecurity incident affecting the reliable operation of the Bulk-Power System.
  • September 27: SEC final amendments to its Rules of Practice that concern, among other things, the timing of hearings in administrative proceedings, depositions, summary disposition and the contents of an answer.
  • September 30: NFA amendments to NFA Compliance Rule 2-46 to impose a $200 late fee on commodity pool operator and commodity trading advisor members for each business day the member files its quarterly NFA Form PQR or PR after the due date.

Compliance Deadlines

  • September 28: CFTC extension of no-action relief available under CFTC Letter 15-52 from September, 2015, for an additional five months for certain of the OCR forms.
  • September 29: FINRA annual audit report filing deadline for the period ending July 31, 2016.
  • September 30: CFTC extension of time-limited no-action relief – originally granted by CFTC letter 14-140 – from transaction-level requirements for Non-U.S. swap dealers.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.