In a comment letter, the Financial Information Forum ("FIF") provided recommendations to the SEC on modernizing Regulation NMS Rule 605 (Disclosure of Order Execution Information). The FIF believes that the SEC should consider revising Rule 605 to better reflect the best practices created by industry participants since the rule’s adoption. The FIF recommended: expanding the scope of covered orders; broadening the "granularity of reporting"; instituting a "Marketable Benchmark" statistic, which would better inform investors of the size of the order relative to the consolidated national best bid

In a comment letter to the Consolidated Audit Trail ("CAT") Leadership Committee, the Financial Information Forum ("FIF") recommended several "logistical changes to the specification" as the Consolidated Audit Trail transitions to a new Plan Processor. The FIF urged the self-regulatory organizations to focus on: the integration of an "Error Correctional Tool that will help facilitate the CAT error repair process in an efficient and timely manner"; the continued review and solution of "specification-related issues" identified by industry members, including, but not limited to: (i) "finalizing

The Consumer Financial Protection Bureau ("CFPB") clarified its proposal to create a "Disclosure Sandbox." The proposal is intended to encourage companies to create tailored consumer disclosures that may be more effective than those required by law. The CFPB clarified that the proposed Disclosure Sandbox would be open to "any covered entity" and not only to "fintech companies." As previously covered, the CFPB proposed amendments to the 2012 "Encourage Trial Disclosure Programs" policy. The comment period for the proposal has passed.

The Consumer Financial Protection Bureau ("CFPB") proposed rescinding the mandatory underwriting provisions of a final rule governing "Payday, Vehicle Title and Certain High-Cost Installment Loans." Additionally, the CFPB proposed to delay the compliance date for the mandatory underwriting provisions of the final rule (originally August 19, 2019) until November 19, 2020. The CFPB proposed to rescind: the "identification" provision, which establishes that it is an "unfair and abusive practice for a lender to make covered short-term loans or covered longer-term balloon-payment loans without

The U.S. District Court for the District of Connecticut ordered a former precious metals trader (the "trader") to pay a $100,000 civil monetary penalty for spoofing and partaking in a deceptive scheme. The CFTC Order arose from a CFTC complaint charging that the trader placed orders in the precious metals futures market with the intention of canceling the orders prior to execution ( i.e., spoof orders). According to the CFTC, the trader intended for his spoof orders "to induce other market participants to transact on smaller, 'Genuine Orders' that [he] placed on the opposite side of the market