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Steven Lofchie Commentary by Steven Lofchie

The SEC Division of Trading and Markets permitted broker-dealers, and over-the-counter derivatives dealers, to file annual and supplemental reports electronically under Securities Exchange Act Rules 17a-5 ("Report to Be Made by Certain Brokers and Dealers") or 17a-12 ("Reports to Be Made by Certain OTC Derivatives Dealers") through the SEC's Electronic Data Gathering, Analysis and Retrieval ("EDGAR") system. In a letter to FINRA, SEC staff stated that by filing electronically through EDGAR, "broker-dealers will avoid the uncertainties, delay, possible processing errors, and expense related to

Steven Lofchie Commentary by Steven Lofchie

The Government Accountability Office ("GAO") reported that community banks, credit unions and industry associations cited an increase in the compliance burden from the Dodd-Frank Act. The GAO report stated that the full impact of the Dodd-Frank Act "remains uncertain because many of its rules have yet to be implemented and insufficient time has passed to evaluate others." The GAO report examined: (i) regulatory analyses by federal agencies and interagency coordination, and (ii) the impact of selected Dodd-Frank provisions and related implementing rules on financial stability. From interviews

The SEC's approved MSRB-proposed Rule G-42 and amendments to Rule G-8 ("Books and Records to Be Made by Brokers, Dealers and Municipal Securities Dealers") as amended by Amendments No. 1 and No. 2. The SEC action was published in the Federal Register.

The MSRB's proposed rule changes to MSRB Rule G-37 ("Political Contributions and Prohibitions on Municipal Securities Business"), G-8 ("Books and Records to Be Made by Brokers, Dealers and Municipal Securities Dealers") and G-9 ("Preservation of Records"), as well as to Forms G-37 and G-37x were published for comment in the Federal Register. The proposal would amend MSRB Rule G-37 in order to safeguard the municipal securities market against pay-to-play practices. The MSRB also proposed related amendments to MSRB Rules G-8, G-9 and Forms G-37 and G-37x.

FINRA's proposed rule change to adopt FINRA Rule 2273 ("Educational Communication Related to Recruitment Practices and Account Transfers") was published in the Federal Register. Rule 2273 would establish an obligation for a member to deliver an educational communication in connection with member recruitment practices and account transfers. Comments should be submitted by January 20, 2016.