Ameriprise 2014 Annual Report Download - page 40

advisers, including the authorization of one or more self-regulatory organizations to examine, subject to SEC oversight,
SEC-registered investment advisers.
In connection with rules adopted by the CFTC, certain of our subsidiaries are registered with the CFTC as a commodity
trading advisor and commodity pool operator and are also members of the NFA, a self-regulatory body under CFTC
jurisdiction. These rules adopted by the CFTC eliminated or limited previously available exemptions and exclusions from
many CFTC requirements and impose additional registration and reporting requirements for operators of certain registered
investment companies and certain other pooled vehicles that use or trade in futures, swaps and other derivatives that are
subject to CFTC regulation. The CFTC or the NFA may institute proceedings and impose sanctions for violations of the
Commodity Exchange Act and applicable rules relating to commodities and commodity-related instruments (including stock
index futures); sanctions may include fines, censure or the suspension or termination of registration or NFA membership. In
2014, U.S. prudential banking regulators and the CFTC proposed rules on margin requirements for uncleared swaps. If
implemented, the proposed rules would impose new requirements upon us related to initial and variation margin. The final
rules are expected to be issued in the second half of 2015.
Outside of the U.S., our Threadneedle group is primarily authorized to conduct its financial services business in the UK
under the Financial Services and Markets Act 2000. Threadneedle is currently regulated by the Financial Conduct Authority
(‘‘FCA’’) and the Prudential Regulation Authority (‘‘PRA’’). FCA and PRA rules impose certain capital, operational and
compliance requirements and allow for disciplinary action in the event of noncompliance.
In addition to the above, certain of our asset management subsidiaries, such as Threadneedle’s UK and other European
subsidiaries, are required to comply with pan-European directives issued by the European Commission, as adopted by E.U.
member states. For example, Threadneedle and certain of our other asset management subsidiaries are required to comply
with the Alternative Investment Fund Managers Directive (‘‘AIFMD’’) and European Market Infrastructure Regulation
(‘‘EMIR’’). These regulations are impacting the way we manage assets and place, settle and report on trades for our
clients, as well as market to clients and prospects. EMIR is the EU equivalent of Title VII Dodd-Frank (and provides a
framework for the regulation of over the counter and exchange-traded derivative markets). EMIR is being implemented in a
number of phases that began in August 2012. We have been engaging with clients, counterparties, trade repositories,
trading platforms and intermediaries to implement the documentation, operational procedures and arrangements needed
to facilitate EMIR compliance for our asset management clients.
In Singapore, our asset management subsidiary Threadneedle Investments Singapore (Pte.) Ltd. (‘‘Threadneedle
Singapore’’) is regulated by the Monetary Authority of Singapore (‘‘MAS’’) under the Securities and Futures Act.
Threadneedle Singapore holds a capital markets services license with MAS, and employees of Threadneedle Singapore
engaging in regulated activities are also required to be licensed. MAS rules impose certain capital, operational and
compliance requirements and allow for disciplinary action in the event of noncompliance.
Threadneedle companies and activities are also subject to other local country regulations in Europe, Dubai, Hong Kong,
Malaysia, Taiwan, the U.S., South Korea and Australia. Additionally, many of our subsidiaries, including Columbia
Management, are also subject to foreign, state and local laws with respect to advisory services that are offered and
provided by these subsidiaries, including services provided to government pension plans. Foreign and state governments
may also institute proceedings and impose sanctions for violations of their local laws, which may include fines, censure or
the suspension or termination of the right to do certain types of business in a state or country.
ATC is primarily regulated by the Minnesota Department of Commerce (Banking Division) and is subject to capital adequacy
requirements under Minnesota law. It may not accept deposits or make personal or commercial loans. As a provider of
products and services to tax-qualified retirement plans and IRAs, certain aspects of our business, including the activities of
our trust company, fall within the compliance oversight of the U.S. Departments of Labor and Treasury, particularly
regarding the enforcement of the Employee Retirement Income Security Act of 1974, as amended (‘‘ERISA’’), and the tax
reporting requirements applicable to such accounts. ATC, as well as our investment adviser subsidiaries, may be subject to
ERISA, and the regulations thereunder, insofar as they act as a ‘‘fiduciary’’ under ERISA with respect to certain ERISA
clients.
Insurance Regulation
Our insurance subsidiaries are subject to supervision and regulation by states and other territories where they are
domiciled or otherwise licensed to do business. The primary purpose of this regulation and supervision is to protect the
interests of contractholders and policyholders. In general, state insurance laws and regulations govern standards of
solvency, capital requirements, the licensing of insurers and their agents, premium rates, policy forms, the nature of and
limitations on investments, periodic reporting requirements and other matters. In addition, state regulators conduct periodic
examinations into insurer market conduct and compliance with insurance and securities laws. The Minnesota Department
of Commerce, the Wisconsin Office of the Commissioner of Insurance, and the New York State Department of Financial
Services (the ‘‘Domiciliary Regulators’’) regulate certain of the RiverSource Life companies, and the Property Casualty
companies depending on each company’s state of domicile. In addition to being regulated by their Domiciliary Regulators,
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