The reopening of the comment period for the CFTC position limits for derivatives and aggregation of positions proposals was published in the Federal Register. The comment period will open on December 9, 2014, and close on January 22, 2015. See: 79 FR 71973. Related news: CFTC Reopens Comment Period for Proposed Position Limits Rule (with Lofchie and Zwirb Comments) (December 1, 2014); CFTC Extends the Comment Period for Certain Aspects of Proposed Rules on Position Limits and Aggregation (Fed. Reg.) (July 3, 2014); CFTC Further Extends the Comment Period for Proposed Rules on Position Limits

Experts at NERA Economic Consulting issued a quantitative impact study to analyze the potential costs and benefits of the CFTC's proposed rule on initial and variation margin requirements of uncleared swaps for swap dealers and major swap participants. According to the NERA study: the aggregate incremental opportunity costs of the proposed margin requirements in normal markets are substantial, estimated at $411 million per year; several aspects of the proposed rule are pro-cyclical and thus will likely increase systemic risks rather than mitigate them, including monthly recalibration of

The NFA issued a Notice to Members providing guidance to entities operating under an exemption or exclusion from CPO or CTA registration regarding the CFTC annual affirmation requirement. According to the Notice, the CFTC requires any person or entity claiming an exemption or exclusion from CPO or CTA registration under CFTC Rules 4.5, 4.13 or 4.14 to annually affirm the applicable notice of exemption or exclusion within 60 days of the calendar year end, or March 2, 2015 for this affirmation cycle. Beginning December 3, 2014, any entity claiming an exemption or exclusion from CPO or CTA

Mercatus Scholar and former Congressional and SEC staff attorney Hester Peirce posted a commentary titled " Regulators Foist Do as We Say, Not Do as We Do on Wall Street," arguing that financial regulators' hold themselves to less demanding standards than those they apply to their regulated entities. According to Ms. Peirce, the SEC's microphone malfunction during the meeting adopting Regulation SCI, which requires stock exchanges and market infrastructure providers to ensure that their technology functions properly, is a symbol of the problem that "too often, regulators writing and enforcing

FINRA fined JP Morgan Securities for overly concentrated short positions in U.S. Treasuries made by one of its brokers for two clients. See: FINRA Dispute Resolution; BrokerCheck Report.