SIFMA sent a letter to the SEC to request a review of the regulatory structure of broker-dealers, exchanges, and the SRO model. SIFMA Executive Vice-President Randy Snook acknowledged that the current SRO structure "is widely viewed to be outdated and in need of reform." In its letter, SIFMA suggested the following key areas it believes the SEC should consider during its review: What is an exchange and why is it an SRO?; Examine the competition between exchanges and the broker-dealers they regulate; Competitive and regulatory disparities; and Funding of self-regulation Lofchie Comment: The

SIFMA has submitted supplemental comments to the SEC regarding recently approved amendments to FINRA Rule 8313 (the "Proposal"), which governs the disclosure of disciplinary and other information by FINRA to the public. The Proposal includes disclosures about Expedited Proceeding under FINRA Rule 9554, as to which SIFMA had previously submitted comments. The SEC approved the FINRA rule on June 21, 2013, acknowledging that, "FINRA did not address concerns raised by the SIFMA Letter that were outside the scope of the proposed rule." SIFMA is now requesting that the SEC address the disclosure

FINRA addressed several trade reporting issues in connection with reporting transactions in TRACE-eligible securities to the Trade Reporting and Compliance Engine ("TRACE") system. FINRA addressed the following topics: Split-volume reporting; Reporting investment adviser-directed transactions; Reporting Securities Act Regulation S transactions; Transfers establishing the underwriting syndicate; Firm commitments prior to final pricing; Transfers facilitating settlement; and Reporting collateralized mortgage obligations. See: FINRA Trade Reporting Notice.

The SEC announced that Kathleen Weiss Hanley, Deputy Chief Economist and Deputy Director of the Division of Economic and Risk Analysis, is leaving the agency. Dr. Hanley will join the faculty at the University of Maryland's Robert H. Smith School of Business. See: SEC Press Release.

The SEC sanctioned two investment advisory firms for failing to seek best execution on client trades placed with their affiliated or related brokerage operations. A.R. Schmeidler Co. ("ARS") and Goelzer Investment Management ("GIM") were cited, respectively, for failing to reevaluate whether it was providing best execution for clients, and for misrepresentations in its Form ADV about the process of selecting a broker for advisory clients. ARS has agreed to pay $1 million to settle the damages, while GIM has agreed to pay nearly $500,000. Lofchie Comment: The press release seems intended to