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Commentary by Steven Lofchie

The SEC proposed to (i) expand the definition of "exchange" under SEA Rule 3b-16 to include systems that only display "trading interest" (as opposed to "orders") including by use of "communication protocols"; and (ii) remove the exemption that Regulation ATS currently provides to systems that trade only government securities.

In three separate notices, NFA reminded (i) futures commission merchants, forex dealers, and introducing brokers, (ii) CPOs and CTAs, and (iii) swap dealers on reporting requirements, and common deficiencies in regulatory compliance.