The Office of the Comptroller of the Currency ("OCC") issued a revised and reorganized guidance for subordinated debt issued by national banks. The revised guidance is located at appendix A of the "Subordinated Debt" booklet of the Comptroller's Licensing Manual. See: OCC Updated Guidelines for Subordinated Debt; OCC Press Release.

In a blog post titled, "BATS in the OCC's Belfry? or The Perils of Natural Monopoly Regulation, CCP Edition," University of Houston finance professor Craig Pirrong discussed the dispute surrounding the Options Clearing Corporation ("OCC") new capital plan. Pirrong states that BATS, other non-owner exchanges and market users are concerned that the capital plan "allows OCC's owners to 'monetize' the rents accruing to its status as the monopoly clearer for options transactions in the U.S." He explained that non-owner exchanges and market users believe that OCC will pay for dividends received from

The Asset Management Group of SIFMA provided comments to the SEC that supported the Bloomberg application for exemption from registration as a clearing agency in connection with the proposed Bloomberg STP confirmation matching service. See: SIFMA AMG Comment Letter.

The Asset Management Group of SIFMA ("SIFMA AMG") submitted comments to the U.S. Treasury Department, the SEC, the Board of Governors of the Federal Reserve System ("FRB") and the CFTC regarding the publication of the second consultative document by the Financial Stability Board ("FSB") and the International Organization of Securities Commissions ("IOSCO"). The document is titled " Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important Financial Institutions" ( see also IOSCO press release). In the letter, SIFMA AMG criticized the Second Consultative

The SEC's proposal to amend Exchange Act Rule 15b9-1 to require broker-dealers trading in off-exchange venues to become members of a national securities association ( i.e., FINRA) was published in the Federal Register. The proposed amendments would replace the current gross income allowance in the rule with a narrower exemption from national securities association membership for brokers or dealers that carry no customer accounts and effect transactions on a national securities exchange. The amendments would create an exemption for (i) a dealer that effects off-exchange transactions solely for