SIFMA submitted comments to the SROs responsible for developing and implementing a consolidated audit trail ("CAT"). The CAT will collect and identify every order for all exchange-listed equities and equity options across all U.S. markets. In its letter, SIFMA stated that the SROs' decision to seek requests for proposals for the CAT's data processor was premature because: The details of the SROs' NMS Plan for implementing the CAT are too vague to elicit meaningful proposals for the CAT's data processor; No procedure is in place to prevent conflicts of interest from SROs who intend to submit

GAO issued a report in which it reviewed the progress of financial regulatory reform. According to the finding, implementation of reform is being delayed by the number, complexity and interconnectedness of the issues to be addressed, as well as a fragmented regulatory structure. Lofchie Comment: While the report is explicitly about the progress of Dodd-Frank rulemaking, it is implicitly a negative comment on the organization of our regulatory system and on the the "benefits" of Dodd-Frank. As to the regulatory structure, I quote from the GAO Report (page 3 in the Highlights): "The efficiency

The SEC Division of Trading and Markets issued a no-action letter regarding the classification of certain persons as owners of broker-dealers for purposes of Exchange Act Rules 15c3-1 and 15c3-3. Owners of a broker-dealer are not “customers” for purposes of the customer protection provisions of Exchange Act Rule 15c3-3. The letter sets forth facts and conditions sufficient to allow a person to be classified as an owner for purposes of Rule 15c3-3 and for that person’s capital contribution to be treated as a capital contribution under Exchange Act Rule 15c3-1 (the net capital rule). Lofchie

The SEC Division of Investment Management provided no-action relief to Pacholder High Yield Fund, Inc. ("Fund") for the following reasons. Under Rule 14a-8(f)(1), a company may exclude a shareholder proposal if the proponent is not the record owner and fails to provide appropriate proof of eligibility in accordance with the eligibility requirements of Rule 14a-8(b)(2), provided that the company timely notifies the proponent of the deficiency and the proponent fails to correct the deficiency within the required time period. According to the letter, the proponent did not provide the required

This notice provides information as to newly elected Board members in those categories and a complete list of the members of the 2013 Nominating Committee. View Notice in full here (links externally to NFA website).