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Congressman Scott Garrett (R-NJ), Chairman of the Financial Services Subcommittee on Capital Markets and Government-Sponsored Enterprises, issued a statement questioning the FINRA-proposed rule to implement the Comprehensive Automated Risk Data System ("CARDS"). Representative Garrett stated that he remains "far from convinced" that a new "burdensome" proposal is needed, and questions whether the purported benefits justify the costs. See: Press Release.

The FINRA-proposed rule change to revise the operative date for the deletion of FINRA Rule 7740, pursuant to a previous FINRA rule change, was published in the Federal Register. FINRA Rule 7740 sets forth the fees to be paid by the purchaser of historical research reports regarding OTC Bulletin Board ("OTCBB") securities through the OTCBB website. FINRA filed for the deletion of Rule 7740 in SR-FINRA-2014-032, along with amendments to Rule 7710 relating to fees for the OTC Reporting Facility. In response to requests by the industry, FINRA delayed the amendments to Rule 7710 until November 17

Steven Lofchie Commentary by Steven Lofchie

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued self-executing registration no-action relief for certain commodity pool operators ("CPOs") who delegate certain activities to another registered CPO. The relief is contained in CFTC Letter 14-126 ("Revised Letter") which supersedes DSIO's prior letter on CPO delegations set forth in CFTC Letter 14-69 ("Original Letter"). Specifically, the Revised Letter provides relief from CEA Section 4m(1) to a person who has delegated certain responsibilities as a CPO ("Delegating CPO") of a commodity pool to another person who is

At the Securities Enforcement Forum, SEC Commissioner Michael Piwowar discussed his perspective on the ways in which the SEC handles enforcement matters. According to Commissioner Piwowar, persons should be "on notice" as to what acts, or failures to act, constitute violations of the law, and what potential sanctions and liabilities will result from those violations. In administering securities laws, Commissioner Piwowar asserted, the SEC faces the issue of increasingly complex laws and rules that govern the markets. He noted, however, that more regulations do not necessarily result in better