SIFMA submitted comments to the SEC regarding the International Securities Exchange's ("ISE") proposed rule change to amend ISE Rule 722, with the stated intention to "prohibit certain types of complex orders from legging into the regular market." "Legging" as described in the letter, means "executing against individual quotes for each of the legs of the complex orders in the regular market." In the letter, SIFMA stated that it strongly agrees with the proposal, which SIFMA suggested would eliminate a loophole that "allows market maker quotes to trade beyond their risk mitigation settings in

SIFMA and ISDA submitted comments to the CFTC in response to the reopening of comment periods on Position Limits for Derivatives and the Aggregation of Positions. SIFMA and ISDA focused on issues relating to: (i) physical commodity hedges; (ii) the process for providing non-enumerated exemptions from the position limits rules; (iii) spot-month limits and a conditional exemption; and (iv) the aggregation rules. In the letter, SIFMA and ISDA expressed support for the CFTC's decision to reopen the comment period on the Position Limits Proposal and Aggregation Proposal, and endorsed the CFTC's

FINRA filed with the SEC proposed amendments to Rule 9120, including to the definition of "Hearing Officer." This proposal was published in the Federal Register. The FINRA proposal would amend the definition of "Hearing Officer" to include a former employee of FINRA who is a licensed attorney and who is appointed by the Chief Hearing Officer. Additionally, the proposed rule would allow the Chief Hearing Officer to appoint a former employee of FINRA, who acted previously as a Hearing Officer, to act in an adjudicative role and fulfill the various adjudicative responsibilities and duties of a

According to a recent blog post by the Managed Funds Association ("MFA") that cites an article in Pensions Investments, a number of Canadian pension plans and the crown corporations that manage the plans' assets are opening foreign offices to boost their alternative investments outside their home country. As reported in the MFA blog post, the Pensions Investments article notes that several pension plans with billions of dollars in assets have established, or are in the process of establishing, offices in New York, London, Washington, Mexico City, São Paulo, Hong Kong and Singapore. See: MFA

FINRA released an information notice stating that it is revising the process for candidates with limited English proficiency ("LEP") who seek additional time to complete either a qualification examination or a Regulatory Element Continuing Education session ("CE session"). Starting on September 8, 2014, individuals must submit electronically through the Central Registration Depository ("CRD") all requests for candidates with LEP to receive additional time on qualification examinations or CE sessions. FINRA stated that it will no longer accept hard copies of LEP request forms from firms that