At MFA's "Outlook 2014," CFTC Chairman Timothy Massad delivered remarks that focused on cross-border international harmonization. Chairman Massad stated that he shares many of the concerns of market participants about the potential for harm if the derivatives reforms adopted by different jurisdictions are not the same. He reminded market participants, however, that the OTC derivatives industry "grew up to be a global industry without any regulation," and that, inevitably, there will be differences between various G-20 nations. He noted that the CFTC plans to do more in the area of substituted

FINRA amended its Rule 7730 to adopt a limited fee waiver pilot program for the Professional Real-Time Data Display Fee, permitting professionals to access real-time Trade Reporting and Compliance Engine transaction data on a trial basis. See: 79 FR 62221. Related news: FINRA Proposes to Adopt Limited Fee Waiver Pilot Program Pursuant to Rule 7730 (October 3, 2014).

The CFTC issued no-action relief to a CPO from the requirement to have an independent public accountant audit the financial statement of its pool's annual report, pursuant to CFTC Rules 4.7(b)(3)(i) and 4.22(d), for the fiscal year ending on December 31, 2013. The no-action relief was granted under the condition that the CPO must file with the NFA and distribute unaudited financial statements to participants for the fiscal year 2013. See: CFTC Letter 14-128.

SIFMA submitted a comment letter to the SEC regarding proposed amended rules and forms relating to money market funds. The proposed amended rules eliminate references to ratings from Investment Company Act Rule 2a-7 ("Money Market Funds") and modify Form N-MFP. SIFMA provided "six main comments" on the proposals: the SEC should revise the proposed definition of "eligible security" to eliminate the new phrase "which determination [of minimal credit risks] must include a finding that the security's issuer has an exceptionally strong capacity to meet its short-term financial obligations"; the SEC

SIFMA submitted a letter to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, "Agencies") regarding the treatment of municipal securities as High-Quality Liquid Assets ("HQLA") under the Basel III Liquidity Coverage Ratio Rule ("LCR Rule"). According to SIFMA, many investment-grade municipal securities exhibit all of the key characteristics of HQLAs specified in the LCR Rule and retain these characteristics during times of market stress. SIFMA recommended that the Agencies consider a