The CFTC amended Rule 1.35(a) ("Records of Commodity Interest and Related Cash or Forward Transactions") to reduce certain recordkeeping requirements imposed on end-users. The action was published in the Federal Register. In general, the amendments codify existing no-action relief provided by the CFTC staff. The effective date is December 24, 2015. Additional comments on the amended recordkeeping requirements may be submitted until February 22, 2016.

The SEC settled an insider trading case against a former employee of a credit card company. The settlement accepted by the district court alleged that the employee traded on misappropriated inside information illegally obtained from his employer. The defendant agreed to pay $4.7 million in disgorgement, prejudgment interest and civil monetary penalties.

The CFTC proposed amendments to system safeguards rules for designated contract markets ("DCMs"), swap execution facilities ("SEFs"), swap data repositories ("SDRs") and derivatives clearing organizations ("DCOs"). The proposed amendments affect existing provisions relating to system safeguards risk analysis and oversight and cybersecurity testing, and add provisions concerning certain aspects of security testing. The CFTC also requested comment on potential testing requirements for independent contractors. The proposal and the request for comment were published in the Federal Register. The

FINRA proposed expanding the instructions to the Derivatives and Other Off-Balance Sheet Items Schedule ("OBS") pursuant to FINRA Rule 4524 ("Supplemental FOCUS Information"). The proposed instructions include certain non-carrying/non-clearing firms that have significant amounts of off-balance sheet obligations. FINRA noted "considerable principal trading activities" of certain non-clearing firms during an examination of firms' margining practices in "extended settlement" transactions (including TBA transactions). FINRA stated that it is concerned about firms appropriately monitoring their

FINRA provided an overview of securities-backed lines of credit ("SBLOCs"), a product increasingly offered by securities firms to investors. The investor alert explains: (i) what SBLOCs are; (ii) how they work; (iii) credit limits; (iv) related interest rates and repayments; and (v) weighing potential advantages and risks. The alert recommends investors ask the following questions before taking out an SBLOC: When I take out an SBLOC, what am I agreeing to? Who is the lender? Should I use my investments as collateral? What if the value of my portfolio decreases? Does my investment mix matter