FINRA filed a proposed rule change to extend the pilot program in FINRA Rule 6730(e)(4) ("Transaction Reporting") to October 23, 2015. The pilot program exempts TRACE-Eligible Securities transactions that are executed on a facility of the NYSE from reporting to the Trade Reporting and Compliance Engine ("TRACE"). See: Text of Proposed Rule Change; FINRA Press Release. See also: FINRA Releases FAQ Regarding TRACE Reporting (August 1, 2013); FINRA Announces Increased Transparency in Mortgage-Backed Securities Market through TRACE (July 22, 2013); FINRA Proposed Rule Change: Dissemination of

The CFTC filed and settled charges against a certified public accountant for failing to audit a financial group in accordance with CFTC Regulation 1.16 ("Qualifications and Reports of Accountants"). Jeannie Veraja-Snelling was the auditor for Peregrine, an FCM whose CEO, Russell Wasendorf, was convicted of fraud in July 2012 in connection with a shortfall of approximately $200 million. The CFTC alleges that Wasendorf was able to commit and conceal his fraud because Peregrine lacked proper accounting controls. Furthermore, the CFTC found that Veraja-Snelling's audits of Peregrine were not

The Asset Management Group of SIFMA provided comments to the CFTC on the recent CFTC guidance and exemptive order relating to cross-border swap activities. The SIFMA letter, among other things: asks for additional time to comply with the "U.S. person" definition (until December 21, 2013 for assessment and identification and March 31, 2014 for compliance); seeks an explicit recognition by the CFTC that asset managers have the discretion to determine in good faith, based on the facts and circumstances that they deem most relevant, whether a fund's principal place of business is in the U.S.; asks

The U.S. Court of Appeals in D.C. designated November 25, 2013 at 9:30 A.M. as the date and time for oral arguments, relating to the CFTC's proposed position limits rules, in the case of ISDA and SIFMA v. CFTC. See: U.S. Court of Appeals Announcement. See also: ISDA v. CFTC: Court Vacates Position Limits Rule (with Lofchie Comment) (with music from the Eastern Institute of Technology) (September 28, 2012).

The Board of Governors of the Federal Reserve System ("FRB") published a final rule in the Federal Register implementing Section 318 ("Funding") of the Dodd-Frank Act. The new rule directs the FRB to collect assessments, fees, or other charges equal to the total expenses the Board estimates are necessary or appropriate to carry out its supervisory and regulatory responsibilities. See: 78 FR 52391. See also: FRB Issues Final Rule Establishing Large Financial Companies' Annual Assessment Fees (August 16, 2013); Three Federal Bank Agencies Seek Comment on Dodd-Frank Act Stress Test Guidance for