In this two-part series on the continuing education counsel's fall 2012 firm element advisory, FINRA is providing guidance on several regulatory and sales practice issues that firms should consider when creating their training programs. Topics include: Municipal Securities An issued guidance stating that G17 also applies to underwriters of municipal securities; A new MSRB Rule (eff. 12/22/2012) affirms duty of a broker's broker to make a reasonable effort to obtain a fair, reasonable price for municipal securities; MSRB amended its record-keeping rule; MSRB revised definition of a

"Dear Chairman Gensler, I have many questions . . . ," is the second series of questions posed by John Sodergreen, editor-in-chief of the Energy Metro Desk, which is addressed primarily to CFTC staffers. The questions request "down-in-the weeds details" that Metro Desk's readers might have regarding compliance with Dodd-Frank requirements "in the hopes that some CFTC staffer" will read them and respond "with some clarity on the subject." This week's edition includes questions relating to Client Chronic Fatigue Syndrome regarding proposed compliance deadlines, and ad hoc no-action actions by

The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") issued the attached time-limited no-action letter providing relief for persons engaging in floor trader activities. During that limited time period, DSIO will not recommend that the CFTC take an action against an entity for failure to include, in its calculation of the aggregate gross notional amount of swaps connected with its swap dealing activity for purposes ofCFTC Rule 1.3(ggg)(4), a swap that is submitted for clearing to a registered derivatives clearing organization, provided that: the entity does not have a

The CFTC's Division of Market Oversight ("DMO") issued the attached no-action letter providing time-limited relief to SDs and MSPs from the obligation to report swap data under CFTC Rules Part 45 (Swap Data Recordkeeping and Reporting Requirements) for cleared credit default swaps ("CDS") that are entered into pursuant to a derivatives clearing organization's ("DCO") rules related to its price submission process for determining end-of-day settlement prices for cleared CDS. The no-action letter provides that the DMO will not recommend that the CFTC take action against a reporting counterparty

The CFTC has announced and notified ICE Futures U.S. of the results of a rule enforcement review completed by the CFTC's Division of Market Oversight. The Division assessed the Exchange's compliance with new Core Principle 13, which relates to the Exchange's disciplinary program. The Division found that the Exchange maintains an adequate disciplinary program, although the Division did make a number of suggestions as to refinement of the program. Click here to view report in full (links externally to CFTC website).