SIFMA members submitted comments to the U.S. Department of Treasury and the IRS on a number of issues identified in the final regulations of the FATCA. One issue stressed in this letter is that the financial industry's IT systems will not be ready for the January 1, 2014 effective date. See: SIFMA Comment Letter.

SIFMA CEO, Judd Gregg, issued a statement expressing SIFMA's support of Treasury Secretary Jack Lew's call for legislation to improve cyber security efforts in the United States. Mr. Gregg urged Congress to pass legislation that promotes the timely sharing of threat information between the U.S. government and private sector firms. See:SIFMA Statement.

The House Financial Services Committee Chairman Jeb Hensarling (R-TX) stated that he welcomed the United States Supreme Court's announcement of its decision to hear a case over the validity of President Obama's "recess appointments" of three individuals to the National Labor Relations Board ("NLRB") on January 4, 2012. According to Representative Hensarling, the Court's decision regarding the constitutionality of the NLRB appointments will effectively determine the constitutionality of Richard Cordray's appointment to head the CFPB. See: Financial Services Committee Announcement.

IOSCO just released their final report on Principles for the Regulation of Exchange Traded Funds. The report contains nine principles intended to guide the regulation of ETFs. The report states that it is a response to the sharp increase in interest worldwide in assets managed under ETF structures. Lofchie Comment: The opening pages of the report contain a nice summary of certain of the basic concepts around ETFs. The regulatory recommendations seem generally consistent with existing principles of U.S. securities regulations. See: IOSCO Final Report.

FINRA filed with the SEC a series of proposed rule changes to adopt a consolidated set of FINRA supervision rules. The rule change would largely replace existing supervision rules with a new, more flexible set of supervision rules. These amendments are intended to enable FINRA member firms to tailor their procedures to reflect their business, size and organizational structure. Lofchie Comment:Although none of the individual changes appear material, there are quite a number of small changes, as well as changes in the relevant rules. Accordingly, many of a firm's compliance procedures will have