June 30, 2013 is the compliance date for the portfolio reconciliation and swap trading relationship documentation requirements set forth in CFTC Rules 23.502 ("Portfolio reconciliation") and 23.504 ("Swap trading relationship documentation"). Accordingly, provisionally registered swap dealers ("SDs") and major swap participants ("MSPs") are required to submit policies and procedures relating to those requirements no later than Monday, July 1, 2013 (but the NFA cautioned that earlier would be better). Registrants are not required to submit policies and procedures with respect to trades with non

Commissioner Chilton focused on the regulation of "market cheetahs" (high-frequency traders) in his keynote address to the Trading Show Chicago 2013. Chilton highlighted HR 2292, the PROTECT Act, sponsored by Congressman Ed Markey, which would require registration, testing, kill switches, and increased penalties for violations of the CEA by high-frequency traders. Chilton also discussed what he views as several problems and potential solutions associated with high-frequency trading: The volume of trading done by cheetahs today; Potential problems associated with fantasy liquidity created by

The SEC has approved amendments to MSRB Rules G-37 ("Political Contributions and Prohibitions on Municipal Securities Business") and G-8 ("Books and Records to Be Made by Brokers, Dealers, and Municipal Securities Dealers"), requiring additional public disclosure of information related to broker, dealer, and municipal securities dealer contributions to ballot campaigns. The Rule G-37 amendments will add greater specificity to public disclosures concerning contributions made by dealers and dealer personnel to bond ballot campaigns and any municipal securities business awarded as a result of the

The NFA announced an amendment to the Financial Requirements Section 1(a) to set forth an additional alternative minimum adjusted net capital requirement, of at least $20 million, that applies to an FCM that acts as a counterparty to a forex transaction with an eligible contract participant (ECP). All FCMs will be required to address questions in the Supplemental Schedule that they must file for June as to their forex transactions. See: NFA Announcement.

MFA reported on a recent op-ed by Michel Barnier, European Commissioner for Internal Market and Services, in which he observes that the next challenge to global financial regulators is to use the reforms enacted since the financial crisis as the foundation for a single, global framework. Commissioner Barnier uses derivatives as an example of how this relationship could work, and insists that the EU and the U.S. must take the lead in protecting the global economy. Lofchie Comment : Commissioner Barnier's remarks are clearly intended to be a statement of disagreement with the positions advanced