In this issue:

- Nallengara to Replace Cross as Corp. Fin. Chief

- FINRA Rule Relating to Private Placements of Securities Effective December 3

- Additional Guidance on FINRA’s Suitability Rule

- No-Action Relief Granted with Respect to Classification of Certain Persons as Owners of Broker-Dealers for Purposes of the Net Capital and Customer Protection Rules

- No-Action Letter Regarding Definition of “Ready Market” with Regard to Foreign Equity Securities Pursuant to SEC Rule 15c3-1(c)(11)(i)

- SEC Issues Exemptive Order in Connection with Portfolio Margining of Cleared Swaps and Security-Based Swaps

- CFTC Extends Compliance Dates for Certain Swap Dealer and Major Swap Participant Requirements

- CFTC Issues No-Action Letters Relating to Swaps

- Exemption from NFA Assessment Fee for Proprietary Trading Firms that Register as CPOs

- NFA Provides Bylaw 1101 Guidance to Commodity Pool Operators of Investment Companies

- SEC Charges Eight Mutual Fund Directors for Failure on Valuations

- Head of SEC Enforcement Division’s Asset Management Unit Addresses Hedge Fund Enforcement Priorities

- District Court Rules that Individual LLC Member Is Third-Party Beneficiary and Bound by Arbitration Agreement

- Significant New Fees for Group Health Plans in 2014–2016

- European Commission Adopts AIFMD Level 2 Regulation

- European Commission Adopts EMIR Technical Standards on OTC Derivatives

An excerpt from "Significant New Fees for Group Health Plans in 2014–2016"

The Department of Health and Human Services (HHS) issued proposed regulations in the Federal Register on December 7 which provide guidance regarding the Transitional Reinsurance Program (the Program). The Program will be effective for three years: 2014–16. It will impose heavy fees upon employer-sponsored health care plans, whether insured or self-insured.

Please see full newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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