The CFTC issued for public comment a proposed form of a Swaps Report that is intended to offer the public a comprehensive view of the size, risks and activities in the swaps market. The proposal for this new market transparency initiative grew out of the Dodd-Frank swaps market reforms. The CFTC stated that, while Dodd-Frank only requires the Commission to publish a report on swaps market trading, clearing, participants, and products on a semiannual and annual basis, the agency elected to publish this information on a weekly basis in order to afford market participants and the public "a more

SIFMA submitted the attached fairly extensive comments to the Government Accountability Office ("GAO") on the GAO Study of Custody Rule Costs. The study is required by Dodd-Frank Section 412, and is intended to highlight the compliance costs that registered investment advisers incur to comply with Rule 206(4)-2 (the "Custody Rule") under the Advisers Act, as well as the costs which advisers might incur if the surprise-examination exemptions under the Custody Rule were eliminated. SIFMA stated that it is concerned that the application of certain provisions of the Custody Rule, under the

Amendments to NFA Financial Requirements Section 13, which codified NFA's requirement that FDMs file monthly operational and risk management reports and quarterly reports containing CFTC-required performance disclosures, became effective. The amendments also provide that any of these reports which are filed after their due date must be accompanied by a fee of $200 for each business day the report is late. The first monthly operational and risk management report, and the first quarterly report, were due on October 23, 2012. Reports filed after this due date must be accompanied by a fee of $200

ICE Clear U.S. released a notice stating that clearing members should be aware the CFTC has granted an extension from November 8, 2012 to January 15, 2013 as the effective date to comply with the CFTC's Gross Customer Margin (GCM) requirement. As a result of the extension, the ICE Clear U.S. Platform release has also been delayed. The new implementation date has been scheduled tentatively for Saturday, January 12, 2012. View notice in full here (links externally to ICE website).

The Financial Stability Oversight Council issued a significant report, including three major (and non-exclusive) recommendations for material changes in the manner in which money market funds ("MMFs") operate, all with the intended purpose of forestalling a run on MMFs of a type that may trigger a market crash. FSOC's summary of the three proposals is as follows: Alternative One: Floating Net Asset Value. Require MMFs to have a floating net asset value ("NAV") per share by removing the special exemption that currently allows MMFs to utilize amortized cost accounting and / or penny rounding to