SIFMA provided the following comments to the SEC on the "Notice of Filing of Proposed Amendments to the Real-Time Transaction Reporting System Information System and Subscription Service" (File Number SR-MSRB-2012-07), a proposal by the MSRB related to large-size trade reports on the MSRB's Real-Time Transaction Reporting System (RTRS). In this letter, SIMFA states its support for the MSRB Proposal and urges the SEC to approve the rule change as proposed, but without assuming that further changes to the rule will be made. View comment letter here (links externally to SIFMA website).

In a speech at SIFMA's 15th Annual Market Structure Conference, Commissioner Gallagher suggests that the basic premises on which the self-regulatory framework was developed (in the context of private, mutualized exchanges) no longer hold. He goes on to state that the SEC needs to reconsider the role of exchanges as SROs, and questions whether FINRA has become a "deputy SEC." And if it is the case that FINRA has developed into a deputy SEC, Gallagher asks the following: Should FINRA's regulatory responsibility be expanded beyond the broker-dealer industry, "such as regulating investment

Last month, ICE submitted amendments to Chapter 6 of its Rules to conform them to the CFTC’s Position Limits Rules. ICE has announced that it is withdrawing sections of the filing related to the CFTC's Position Limits Rules, which have since been vacated by the U.S. District Court for the District of Columbia. The amendments were intended to add provisions related to Energy Contracts, as well as clarify and provide consistency to certain other Rules. While ICE has withdrawn amendments specifically related to the CFTC's vacated Position Limits Rules, other amendments to Rules 6.13, 6.14(b), 6

The ICE Futures Exchange has announced that it will implement amendments to the Error Policy to provide for No Cancellation (“NCR”) and Reasonability Limit (“RL”) levels for the financial gas, power and emissions futures and options contracts. This will become effective Monday, October 15, 2012. Lofchie Comment: These policies have become extremely important in the securities market where an electronic trade has been mistakenly executed by a HAL 9000 gone haywire. They were the subject of some discussion in connection with the blow-up at Knight, where the regulators determined to break only

NFA Rule 402 (Waiver of Testing Required) had been amended, effective as of October 3, 2012. View amended rule here (links externally to NFA website).