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The SEC is amending interim final temporary Rule 15b12-1T under the Exchange Act to extend the date on which the rule will expire from July 16, 2012 to July 16, 2013. [Lofchie Comment: The questions to which we all want answers: What is an "extension of a final temporary rule"? Is that different from an extension of an "interim final temporary rule"? And what is the interim between? More seriously, this interim final temporary rule is further reflective of the myriad unintended consequences of Dodd-Frank. No one is quite sure of whether routine currency exchanges in connection with routine

This Small Business Review Panel Report addresses the CFPB's upcoming proposal concerning mortgage servicing rulemaking. The Dodd-Frank Act imposes certain requirements concerning mortgage servicing that become self-executing and enforceable on January 21, 2013, unless final rules are issued on or before that date. The CFPB is also considering whether to propose additional requirements as to servicer information management and communications with troubled or delinquent borrowers. Cross Reference(s) : Dodd-Frank Sections 1418, 1420, 1463, and 1464. View study here (links externally to CFPB

SIFMA and NetCoalition provide comments to the SEC on a proposed rule change establishing a fee for television distribution of the NYSE MKT Trades Data Product. In the letter the groups petition the SEC to temporarily suspend this rule change under certain provisions of the Exchange Act, citing that NYSE MKT's actions relate to what the SEC refers to as "core" data, and are inconsistent with the findings of the United States Court of Appeals for the District of Columbia Circuit in NetCoalition v. Securities and Exchange Commission . [Steven Lofchie Comment: This is another chapter in the

The Institute of International Bankers (the “IIB”) has submitted comments to the Commodities Future Trading Commission (the “CFTC”) in response to the CFTC’s proposed Exemptive Order concerning compliance with certain swap regulations. The Order, issued July 12, proposed granting temporary relief to non-U.S. swap dealers and non-U.S. MSPs from certain entity-level and transaction-level requirements, and also proposed granting temporary transaction-level relief to the foreign branches of U.S. swap dealers and MSPs. In submitting their comments on the Order, the IIB expressed several underlying

The SEC charged an investment manager, David W. Dube, and his firm, Peak Wealth Opportunities LLC, for failing to provide SEC examiners with records of a mutual fund advisory business that invested in NASCAR-related stocks. Despite repeated requests, the firm failed to furnish certain records to the SEC. Among other violations, the firm failed to provide the fund's board of directors with information reasonably necessary to assess the firm's advisory fees. Cross-Reference(s): ICA Sec 15(c); IAA Rule 203A-1(b)(2), 204-1(a)(1), 204-2(a)(1), (2), (4), (5) and (6), Sec 203A and 204 View in full