MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the regulation of electronic trading. In the letter, MFA supports the requirement that intermediaries implement pre- and post-trade risk controls. The primary focus of MFA's letter is as to which types of entities should be subject to which burdens. In regulating electronic trading, MFA believes that there should be an important distinction between an intermediary/vendor that provides electronic connectivity services (i.e., connectivity and routing access to liquidity centers) and end-users

In his speech at the University of Notre Dame Business Law Forum, Commissioner O'Malia provided examples of where the CFTC has failed the "Good Government" test in its rulemakings and "must make immediate corrections". In discussing where the CFTC's rule making process had failed, he focused on the following: Swap Data Reporting Rules; The Proposed Cross Border Guidance; Swap Rules Driving Shift to Regulatory Security of Futures Markets. Lofchie Comment: According to Commissioner O'Malia, the CFTC's rulemaking process has led, or will lead, to "regulatory inconsistencies, blatant mistakes

The federal banking regulatory agencies announced the availability of a regulatory capital estimation tool to help community banking organizations and other interested parties evaluate recently published regulatory capital proposals. The tool will assist these organizations in estimating the potential effects on their capital ratios of the agencies' Basel III Notice of Proposed Rulemaking (NPR) and Standardized Approach NPR. The Basel III NPR focuses primarily on strengthening the level of regulatory capital requirements and improving the quality of capital. The Standardized Approach NPR

The SEC approved amendments to MSRB Rule G-34 concerning the use of the terms in communications about new issues of municipal securities. The amendments will prohibit any broker, dealer or municipal securities dealer (a "dealer") from using the term "not reoffered" or other comparable term or designation, such as the commonly used designation of "NRO," without also including the applicable price or yield information about the securities in any of its written communications, electronic or otherwise, sent by or on behalf of the dealer. The rule change will be effective as of November 1, 2012 for

The SEC is amending interim final temporary Rule 15Ba2-6T, which provides for the temporary registration of municipal advisors under the Exchange Act to extend the date on which Rule 15Ba2-6T (and consequently Form MA-T) will sunset to September 30, 2013. Under the amendment, all temporary registrations submitted pursuant to Rule 15Ba2-6T also will expire no later than September 30, 2013. Effective Date: September 30, 2012. The expiration of the effective period of interim final temporary Rule 15Ba2-6T ( 17 CFR 240.15Ba2-6T) and Form MA-T (17 CFR 249.1300T) is delayed from September 30, 2012