The FINRA-proposed rule change to incorporate NASD Rule 3010(e) ("Supervision – Qualifications Investigated") regarding background investigations into new FINRA Rule 3110(e) ("Responsibility of Member to Investigate Applicants for Registration") was published in the Federal Register. The new rule change to FINRA's rulebook would streamline and clarify rule language, and add a provision to require members to adopt written procedures that are "reasonably designed" to verify the accuracy and completeness of the information contained in an applicant's Form U4 (Uniform Application for Securities

On October 2, 2014, the Managed Funds Association ("MFA") submitted comments to the proposed rulemaking issued by FinCEN in August 2014. In its comments, the MFA supports the FinCEN proposal to exempt SEC-registered investment advisors and entities registered with the CFTC, including commodity pool operators and commodity trading advisors, from an obligation to identify the natural persons who are beneficial owners of legal entity customers. The MFA also favors the proposal to exempt pooled investment vehicles, including hedge funds operated or advised by financial institutions, from the

JPMorgan Chase Co. Office of Regulatory Affairs issued a paper proposing steps required to establish a credible securities and derivatives clearinghouse ("CCP") resolution framework to manage the event of a CCP failure. According to the paper, the "issue of resolution" has become increasingly important given that the use of CCPs in the United States is now mandatory, and there is a larger volume of transactions going through these institutions. Additionally, many CCPs have migrated from being utilities owned by members to private for-profit institutions, introducing a possible conflict between

FINRA filed with the SEC a proposed rule change to amend FINRA Rule 7730(c)(1)(A) to adopt as permanent the limited waiver fee pilot program. The limited waiver fee pilot program provides a one month waiver of the Professional Real-Time Data Display Fee, permitting professionals to access real-time Trade Reporting and Compliance Engine ("TRACE") transaction data on a trial basis. See: Text of the Proposed Rule Change; FINRA Filing Announcement.

FINRA filed with the SEC a proposed rule change to postpone the implementation date of the requirement that ATSs use unique market participant identifiers until February 2, 2015. See: Text of Proposed Rule Change; FINRA Filing Announcement.