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SIFMA submitted the attached comments to the MSRB on revised draft rule amendments and on a revised draft interpretive notice on retail order periods (see MSRB 2012-50) which propose amendments to MSRB Rules G-11 (on primary offering practices), G-8 (on books and records), and G-32 (on disclosures in connection with primary offerings), as well as an interpretive notice concerning the application of MSRB Rules G-17 and G-30 to retail order periods. SIFMA stated that it supports the proposed rule changes to the extent they would protect dealers that "follow issuers' instructions, clarify issuer

As part of the implementation of its policy framework for addressing risks associated with systematically important financial institutions ("SIFIs"), the Financial Stability Board has released three reports as described below: an updated list of global systemically important banks ("G-SIBs"); a progress report on the reform of resolution regimes for global systemically important financial institutions ("G-SIFIs"); and a progress report on steps to increase the intensity and effectiveness of SIFI supervision. Lofchie Comment : There were 8 U.S. "banks" on the list, including Goldman Sachs and

The CFTC complaint alleges that the firm (i) opened accounts for a number of improperly unregulated commodity pools and (ii) allowed an introducing broker to hold what was in effect on omnibus account for underlying accounts of the introducing broker, with the result that the introducing broker was really functioning as an unregistered futures commission merchant (IBs are not allowed to custody client assets). This is at least the second recent disciplinary action (see link to prior action below) in which an FCM has been sanctioned for allowing one of its customers to improperly aggregate

On August 3, 2012, in Regulatory Notice 12-37, FINRA announced that amendments to FINRA Rule 6433 (Minimum Quotation Size Requirements for OTC Equity Securities), which simplifies the existing tier structure, facilitates the display of customer limit orders pursuant to FINRA Rule 6460 (Display of Customer Limit Orders), and expands the scope of the rule to encompass quotations displayed by non-market-makers, would become effective on November 5, 2012. Due to disruptions in normal business operations related to Hurricane Sandy, FINRA has changed the effective date of this amendment from

New rules and rule proposals from BOX, CBOE, FICC, MSRB, NYSE, NYSE Arca, NYSEMKT, OCC, and Phlx. Click on the links to view the SEC's notices of each rule change and proposal. BOX: Effective Immediately - Proposal Regarding Quote Mitigation (See also: Exhibit 5) CBOE: Effective Immediately - Rule Change Related to Extending the FLEX Exercise Settlement Values Pilot CBOE: Effective Immediately - Rule Change to CBSX Rule 53.24 CBOE: Effective Immediately - Rule Change to Amend the Fees Schedule (See also: Exhibit 5) FICC: Effective Immediately - Rule Changes to Clarify a Stated Policy with