MFA and AIMA submitted a joint letter to the CFTC in response to its "Exemptive Order Regarding Compliance with Certain Swap Regulations." The letter asks for a delay in the reporting requirements that might otherwise apply to funds in three circumstances: (i) where a fund that will be deemed a "U.S. person" as of October 10, 2013 under the CFTC Guidance (an "October U.S. Fund") is transacting with an entity that intends to register on December 31, 1013; (ii) where an October U.S. Fund is transacting with a non-U.S. dealer that does not intend to register with the CFTC as of the end of the

FINRA has filed a proposed rule change to amend FINRA Rule 5131 ("New Issue Allocation and Distributions") which is intended to prohibit "spinning": the practice of broker-dealers providing corporate insiders with preferential access to new issue stock in exchange for such insiders directing investment banking business to the relevant broker-dealer. The proposed rule amendment would somewhat simplify the compliance burden on broker-dealers selling new issue stock to private funds and correspondingly would simplify the compliance burdens on private funds seeking to purchase such stock. See

The Futures Industry Association ("FIA"), the Futures and Options Association ("FOA"), and FIA Asia announced the completion of the final bylaw changes needed to form FIA Global. The three associations also announced the founding members of the FIA Global board of directors. See: FIA Global Press Release.

The CFTC announced an Interpretation concerning its authority over retail commodity transactions, as provided by Section 2(c)(2)(D) ("Retail Commodity Transactions") of the CEA. The Interpretation clarifies the CFTC's view of the meaning of "actual delivery" under Section 2(c)(2)(D). See: 78 FR 52426; CFTC Press Release.

The CFTC issued a no-action letter providing time-limited relief to SDs and MSPs from compliance with CFTC Rule 23.502 ("Portfolio Reconciliation") provided that the SDs and MSPs intend to comply with comparable EMIR rules. CFTC Letter 13-50 extends from August 23 to September 15, 2013 the relief from portfolio reconciliation provided by CFTC Letter No. 13-45, contingent upon (i) the SD or MSP intending to comply with the EMIR rules that come into effect on September 15 and (ii) the SD or MSP satisfying the other conditions set forth in CFTC Letter No. 13-45. See: CFTC No-Action Letter 13-50