The North American Securities Administrators Association ("NASAA") announced it is seeking public comment on a proposed model rule and guidance requiring investment advisers to create and implement written procedures to address business continuity and succession planning under the Uniform Securities Act of 1956 and 2002. According to NASAA, the responsibility to maintain business continuity, protect clients from interruptions in an investment adviser's business, and mitigate client harm in the event of a business interruption stems from an investment adviser's recordkeeping and fiduciary duty

MFA issued an update on the status of the CFTC reauthorization legislation (H.R. 4413) and further reported that Senate Agriculture Committee Chair Debbie Stabenow (D-MI) is seeking to include a "user fees" measure in the potential bill. According to the MFA Update on CFTC Reauthorization, attention is on the Senate Agriculture Committee for possible legislative action. Notably, the Update stated that there are indications that Chair Stabenow's staff put together an unreleased draft of CFTC Reauthorization legislation that they have reportedly shared with Ranking Member Thad Cochran (R-MS) and

MFA submitted a response regarding the European Securities and Markets Authority ("ESMA") consultation paper and discussion paper on the implementation of the Markets in Financial Instruments Directive ("MiFID II") and the Markets in Financial Instruments Regulation ("MiFIR"). MFA's responses focused on ESMA's questions regarding the derivatives trading obligation, straight-through processing, transparency requirements, the definitions of algorithmic and high frequency trading, position limits, and inducements. See: MFA's Response. Related news: ESMA Announces Consultation Period for

The Futures Industry Association of Europe ("FIA Europe") filed responses to the European Securities and Markets Authority ("ESMA") regarding its consultation paper and discussion paper on the implementation of the Markets in Financial Instruments Directive ("MiFID II") and the Markets in Financial Instruments Regulation ("MiFIR"). . Related news: ESMA Announces Consultation Period for Implementation of the Revised MiFID II MiFIR (May 22, 2014).

FINRA issued an Election Notice announcing the nomination process to fill two vacancies on the National Adjudicatory Council ("NAC"), which are to be filled by one large firm NAC Member and one small firm NAC Member and would serve three-year terms beginning in January 2015. FINRA's Nominating and Governance Committee nominated Elaine Mandelbaum for the large firm NAC seat and declined to nominate any individuals for the small firm NAC seat. See: FINRA Election Notice.