The CFTC Division of Market Oversight ("DMO") granted time-limited conditional no-action relief to swap execution facilities ("SEFs") from certain data reporting and recordkeeping requirements in relation to confirmations required for uncleared swap transactions executed on or pursuant to the rules of an SEF under CFTC Rule 37.6(b). CFTC Rule 37.6(b) ("Enforceability") requires an SEF to provide each counterparty to a transaction entered into, on, or pursuant to the rules of the SEF with a written record of all terms of the transaction. This written record supersedes any previous agreement and

The CFTC Division of Clearing and Risk issued time-limited no-action relief to the Clearing Corporation of India Ltd. ("CCIL") for failing to register as a derivatives clearing organization ("DCO"), pursuant to CEA Section 5b(a) ("Derivatives Clearing Organizations"). The no-action relief is limited to CCIL's clearing of Indian Rupee-denominated interest rate swaps and Indian Rupee-denominated forward rate agreements for the proprietary trades of prospective U.S. clearing members. The no-action relief is effective until the earlier of either December 31, 2014, or the date upon which the CFTC

SIFMA submitted comments to the SEC regarding the MSRB proposal to amend MSRB Rule G-3. The comment concerns continuing education requirements and in part, recommends that MSRB focus its efforts on the newly regulated/previously unregulated financial advisors. Regarding MSRB's proposal, SIFMA provided four recommendations to the SEC that included the following: MSRB should not de-harmonize its continuing education requirements from FINRA rules. SIFMA explained that existing MSRB continuing education requirements are harmonized with FINRA's Rule 1250(b) ("Firm Element Continuing Education

The North American Securities Administrators Association ("NASAA") announced that it will host its annual conference in Indianapolis, Indiana, from September 14-16 to "identify and discuss the challenges facing investors." The conference will explore diminished capacity, high-frequency trading and state efforts to help small businesses raise capital. Lofchie Comment: One of the topics to be discussed is an "examination of the impact of high-frequency trading on investor confidence and market integrity." It is well documented that the cost to retail investors of trading securities is far lower

MFA submitted two comment letters – one to the Hong Kong Monetary Authority and one to the European Securities and Markets Authority – regarding the authorities' various consultation papers. The comment letter to the Hong Kong Monetary Authority and the SEC was submitted in response to the agencies' joint "Consultation Paper on the Securities and Futures (OTC Derivatives Transactions - Reporting and Record Keeping) Rules." Separately, MFA submitted comments to ESMA, regarding its "Consultation Paper on the Clearing Obligation under EMIR (No.1)," which related to the clearing of interest rate