SIFMA submitted a comment letter to the SEC regarding the MSRB draft amendments to establish professional qualification requirements for municipal advisors. SIFMA explained that persons who are qualified currently to perform municipal securities activities also should be qualified to perform municipal advisor activities. According to SIFMA, the proposed MSRB requirement for separate qualification examinations is unnecessary, since the two qualifications have "substantial overlap" in their functions. Accordingly, SIFMA recommended that, if the MSRB proceeds with developing a new qualification

The NFA issued a Notice reminding its members of the immediately effective amendment to NFA Compliance Rule 2-4 ("Just and Equitable Principles of Trade") regarding swap-related activities. The amendment extends the NFA's ethical standards to NFA Member Swap Dealers and Major Swap Participants, as well as the swap activities of FCMs, IBs, CPOs and CTAs. These ethical standards require NFA members to observe "high standards of commercial honor" and "just and equitable principles of trade" in their conduct of the commodity futures business. Lofchie Comment: The requirements to observe high

FINRA issued a Regulatory Notice regarding Final Renewal Statements for broker-dealers and investment adviser firms and representatives, as well as reports that are now available on FINRA's Web CRD/IARD. The Final Renewal Statements include the following fees: Web CRD system processing fees; FINRA branch office processing fees; exchange maintenance fees; state broker-dealer firm, branch and agent renewal fees; state investment adviser firm, branch and investment adviser representative renewal fees; and FINRA annual statutory disqualification fees for registered individuals. FINRA noted that

In an article posted by Harvard's Kennedy School Review, System Logic consultants Chris Clearfield, Andras Tilcsik and Benjamin Berman discuss inevitable consequences of increasing complexity in the emerging securities markets. Research shows, they argue, that as electronic trading continues to increase in complexity, "unexpected interactions between components" within the stock trading industry can turn even trivial incidents into major meltdowns before operators are able to understand and address nascent errors. According to the article, securities regulators, whose tools of examination and

The SEC approved FINRA-proposed amendments regarding per share estimated values for direct participation program ("DPP"), and unlisted real estate investment trust ("REIT") securities on account statements. Specifically, the SEC approved amendments to NASD Rule 2340 ("Customer Account Statements") to modify the requirements relating to the inclusion of per share estimated values for DPP and REIT securities on account statements. Additionally, the SEC approved amendments to FINRA Rule 2310, which makes corresponding changes to the requirements applicable to members' participation in public