The CFTC is adopting regulations to implement certain provisions of Title VII of the Dodd-Frank Act. Section 731 of the Act added a new Section 4s(i) to the Commodity Exchange Act, which requires the CFTC to prescribe standards for swap dealers (SDs) and major swap participants (MSPs) related to the timely and accurate confirmation, processing, netting, documentation, and valuation of swaps. These regulations set forth requirements for swap confirmation, portfolio reconciliation, portfolio compression, and swap trading relationship documentation for SDs and MSPs. Effective Date: November 13

In this report, the SEC staff announces the recommendation that the Commission not take any further action at this time with respect to: standardizing credit rating terminology; standardizing the market stress conditions under which credit ratings are evaluated; requiring a quantitative correspondence between credit ratings and a range of default probabilities and loss expectations under standardized conditions of economic stress; and standardizing credit rating terminology across asset classes. SEC staff further asserts that it would be more efficient to focus on the rulemaking initiatives

SIFMA has released a comment letter addressed to Spencer Bachus, Chairman of the House Financial Services Committee, expressing support for the Chairman's initiative to explore a "less burdensome legislative alternative" to the Volcker Rule. SIFMA cautions that the Volcker Rule could have substantial adverse effects on the U.S. and global economies, and that it targets activities which did not contribute meaningfully to the 2008 financial crisis. The letter makes three main arguments: (i) Congress should reevaluate the statutory text of Volcker, as the legislative process surrounding it was

SIFMA, along with 25 other trade associations, issued this joint letter opposing current proposals to use eminent domain to take mortgages from residential mortgage-backed securities. SIFMA and the coalition of trade groups are actively working together to advocate against what they believe to be an abuse of the sovereign power of eminent domain, and assert that such actions will cause irreparable damage to the housing market. Lofchie Comment : Leaving aside the substance of the letter and the very serious issues at stake for the economy, I note that the first page of the letter features a

In two related enforcement actions, the SEC charged three former brokers at an Atlanta-based brokerage firm for "churning" the accounts of customers with conservative investment objectives, causing severe investor losses while the brokers collected excessive commissions, fees, and margin interest. The SEC also sanctioned the firm itself and its President for failure to supervise. The turnover ratios at issue were from 8x to 13 times annually. In footnote 2 of the Turner disciplinary action, the SEC indicates that a turnover ratio of 6 times can reflect excessive trading. Lofchie Comment: The