Our Regulatory Tracker is a list of effective dates, comment deadlines, compliance dates and expiration dates for the United States of America.

Effective dates

• October 1: MSRB - Proposed Rule Change Consisting of Amendments to MSRB Rules A-3 and A-6 That Are Designed To Improve Board Governance
• October 1: Comptroller - Community Reinvestment Act Regulations
• October 1: CFTC, Comptroller, FDIC, Fed. Res. Board / Banks and SEC - Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships With, Hedge Funds and Private Equity Funds
• October 1: CFTC, Comptroller, FDIC, Fed. Res. Board / Banks and SEC - Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships With, Hedge Funds and Private Equity Funds; Correction
• October 2: Patent and Trademark Office - Setting and Adjusting Patent Fees During Fiscal Year 2020
• October 5: OFAC - Inflation Adjustment of Civil Monetary Penalties Related to Reporting and Recordkeeping. The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing this interim final rule to further implement the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act 2015, by adjusting for inflation its civil monetary penalties for failure to comply with certain recordkeeping and reporting requirements, which are contained in OFAC's Economic Sanctions Enforcement Guidelines in OFAC's Reporting, Procedures and Penalties Regulations.
• October 14: NCUA - Chartering and Field of Membership.
• October 15: Fed. Res. Board / Banks - Rules Regarding Availability of Information.

Comment deadlines

• October 5: The Department of the Treasury's Office of Foreign Assets Control or OFAC - Inflation Adjustment of Civil Monetary Penalties Related to Reporting and Recordkeeping.
• October 5: Department of Labour and EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights. The DoL is proposing to amend the “Investment duties” regulation issued in 1979 to address the application of the prudence and exclusive purpose duties under the Employee Retirement Income Security Act 1974 (ERISA) to the exercise of shareholder rights, including proxy voting.
• October 9: FINRA - Self-Regulatory Organisations; Financial Industry Regulatory Authority; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Amend the Standardized Membership Application Forms - Form NMA and Form CMA - To Conform to Amendments to the Membership Application Programme Rules as Described in SR-FINRA- 2019-030.

Compliance date

• October 5: FINRA - Exclusive Use of "FinPro" for Collaborative Registering. FINRA will enhance the user interface for the Uniform Application for Securities Industry Registration or Transfer (Form U4).

Expiration date

• October 15: Comptroller - Assessment of Fees. The OCC is adopting an interim final rule to reduce assessments in response to the national emergency declared in connection with coronavirus.

* Cadwalader, Wickersham & Taft can be reached on +1 212 504 6000 or at cwtinfo@cwt.com