The CFTC Division of Swap Dealer and Intermediary Oversight issued a no-action letter to commodity pool operators ("CPOs") of SEC-registered investment companies that trade in commodity interests through wholly owned controlled foreign corporations ("CFCs"). The letter states that the CFTC will not take enforcement action against CPOs of registered investment companies for failure to provide both a report for their CFCs to the NFA pursuant to CFTC Rule 4.27(c) ("Additional Reporting by Advisors of Certain Large Commodity Pools") and a separate annual report pursuant to CFTC Rule 4.22(c) (

The National Futures Association proposed new NFA Compliance Rule 2-49 ("Swap Dealers and Major Swap Participants Regulations") regarding the conduct of swaps dealers and major swap participants. If approved, the amendment would specially provide that any violation by an NFA member of CFTC Regulation 3.3 (Chief Compliance Officer requirements) or Part 23 of the CFTC Regulations (regulations applicable to SDs and MSPs) would be deemed a violation of an NFA requirement. Proposed NFA Compliance Rule 2-49 would also require an NFA member SD or MSP to promptly submit to NFA, upon request, " any

SEC Division of Corporation Finance Director Paula Dubberly is retiring from the agency after more than 20 years of service. See: SEC Press Release.

SIFMA filed a brief opposing the actions of various securities exchanges in raising the fees that they charge for market data products. See: SIFMA Consolidated Brief; SIFMA Press Release.

The NFA submitted amendments to the CFTC regarding NFA Bylaws and Rule 3-17 (Composition of Committees). The amendments would modify the NFA's committee structure in a few respects, but the majority of the changes are to the by-laws, and concern the new types of registrants that would become NFA members, including swap dealers, major swap participants and retail foreign exchange dealers. See: Text of Proposed Amendment.