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Steven Lofchie Commentary by Steven Lofchie

The Chicago-based broker-dealer and investment adviser affiliates of an asset management firm settled SEC charges that they failed to maintain and enforce policies and procedures to prevent the misuse of material nonpublic information. An SEC order ("Order") stated that the affiliates violated Securities Exchange Act Section 15(g)("Registration and Regulation of Brokers and Dealers") and Investment Advisers Act Section 204A ("Prevention of Misuse of Nonpublic Information"), respectively. The Order stated that the broker-dealer and investment adviser affiliates: repeatedly shared information

The SEC Division of Trading and Markets granted no-action relief to Chicago Stock Exchange, Inc. from the "current" national best bid requirement of Reg. SHO, Rule 201 to determine whether a short sale order in a covered security subject to the rule can be executed in the exchange's "Sub-second Non-displayed Auction Process" or "SNAP" Cycle. The relief, which the SEC staff found appropriate to "address the tension between Regulation NMS provisions [Rules 610(d) and 611] and Rule 201," is subject to a number of specified conditions and will allow Chicago Stock Exchange, Inc. to use a reference

FINRA's proposed amendments to rules governing the reporting of over-the-counter transactions in equity securities to FINRA "Facilities" (including the Alternative Display Facility and Trade Reporting Facilities) were published in the Federal Register. The proposal will allow the submission of "clearing-only, non-regulatory reports" relating to previously executed and reported transactions and will exempt such reports from certain reporting requirements under FINRA rules. Comments on the proposal should be submitted by October 27, 2015.