FINRA Regulatory Notice FINRA issued a regulatory notice to alert firms of the SEC's approval of new know-your-customer and suitability rules and to establish the effective date of the new rules as October 7, 2011. New FINRA Rules 2090 (Know Your Customer) and 2111 (Suitability) are modeled after NYSE Rule 405(1) and NASD Rule 2310, respectively. Among other things, the new rules amend the previous rules by (i) applying the suitability rule to investment "strategies" as well as "recommendations"; (ii) expanding the types of information firms must consider in assessing a customer's investment

The Association of Corporate Treasurers The European Commission has been consulting on regulatory arrangements for credit rating agencies ("CRAs"). The ACT submission notes the functions the CRAs perform for issuers and investors. Specifically, the submission: Agrees that excessive "hard coding" of ratings within regulation can cause a herding effect that may be destabilizing, but sees the alternative of using CDS or bond spreads as inappropriate in regulation; Sees no need to change the charging model for sovereign ratings, nor force free disclosure of full sovereign rating reports; Views

SEC Release (FINRA Rulemaking) The SEC declared immediately effective a FINRA proposal to extend a pilot program that does not require TRACE reporting of transactions in TRACE-eligible securities executed on an NYSE facility and reported to the NYSE under NYSE rules. The pilot is extended through July 8, 2011. Date January 7, 2011 Cross References (links may require a Cabinet subscription) SEC Release 34-63673

FINRA Regulatory Notice FINRA issued a regulatory notice to announce that OATS order recording and reporting obligations in FINRA Rules 7410 through 7470 will, effective July 11, 2011, be applicable to all orders in NMS stocks, in addition to OTC equities. The release further announces that an updated edition of the OATS Reporting Technical Specifications will become effective on July 11. Date January 11, 2011 Cross References (links may require a Cabinet subscription) FINRA RN 11-03

CFTC Dodd-Frank Rulemaking The CFTC is issuing a notice soliciting comments on the record retention requirement that is embedded in an interim final rule's reporting requirement that the CFTC adopted pursuant to Dodd-Frank, which requires parties to pre-enactment unexpired swap transactions to report certain information related to such transactions to a swap data repository or to the Commission. Document Number 76 FR 1603 Date January 2011 Cross References (links may require a Cabinet subscription) Dodd-Frank Act, Title VII, Secs. 729 CEA Sec. 2(h)(5)