North American Securities Administrators Association (NASAA) President and Arkansas Securities Commissioner Heath Abshure participated in a news teleconference to discuss the proposed rule with representatives from the AARP, AFL-CIO, Consumer Federation of America, and Americans for Financial Reform. Discussed in the teleconference was the role of NASAA members and the JOBS Act provision, which requires the SEC to amend its Rule 506 to eliminate a ban on the general advertising of private securities offerings. Commissioner Abshure criticized the SEC for abdicating its responsibilities in

NASAA has issued a request for comment on proposed changes to Model Rule 102(f)-3 under the Uniform Securities Act of 1956, and Model Rule 502(c) under the Uniform Securities Act of 2002 (the “performance fee model rules” or the “Model Rules”). These changes will conform these rules to the current exemption under SEC Advisers Act Rule 205-3 for performance fees charged to certain “qualified clients.#8221; Comments Due: December 10, 2012. Cross Reference(s): 1956 Model Rule with Proposed Revisions;2002 Model Rule with Proposed Revisions Parness Comment: These changes will be extremely helpful

IOSCO released the final report Policy Recommendations for Money Market Funds in which proposes recommendations - for the regulation of Money Market Funds ("MMFs") throughout the world. The report contained 15 major recommendations (at page 19) the most important of which are summarized below: Limits on the assets in which they invest and the risks they take Limits on use of repo Must use fair value accounting Must disclose to investors the possibility of principal loss Additional requirements should apply to funds that have a "stable" market value; e.g. funds that price at a buck Funds should

CFTC Chairman Gary Gensler made a speech proclaiming "the new era of transparency and commonsense rules of the road for the swaps market." Chairman Gensler discusses several steps that will be taken to further the swaps market reform structure. He argues that the foundation for transparency and lowered risk of the swaps market has finally been laid. For instance, real-time public reporting and reporting to swap data repositories (SDRs) of interest rate and credit default swap (CDS) indices will be achieved by the New Year. Swap dealers will also begin the process of registering and come under

The CFTC staff is responding to questions from market participants and other interested parties as to the timing of when counterparties will be required to report swap pricing and transaction data as required under the Commission's Regulation Part 45. The CFTC is issuing a Q&A document to help market participants better understand the rule, the reporting that is required and who has the obligation to report. The first seven questions deal primarily with when reporting is first required under the Part 45regulations. Questions 8 and 9 deal with the reporting of historical swaps underPart 46