The delay was motivated, at least in part, by concerns as to the substantive requirements of the regulations. Accordingly, FINRA should be receptive to comments on the substantive requirements.

If the world operated in some logical fashion (and if horses had wings), TBA margin rules should be put on hold so that their adoption and implementation could be coordinated with the security-based-swap margin rules given the similarities of the issues (i.e., margin on both TBAs…

FINRA had recently launched a as to recommendations to purchase certain share classes issued by mutual funds.  It may be expected that firms that fail to self-report will risk disciplinary actions.  See, e.g., .  

This is a warning signal.  Firms running an ATS should consider the implications of the report for any ATS it runs, in terms of attracting business, regulatory risk relating to conflicts of interest, and customer risk in terms of disclosure and best execution.

The list contains a number of important big-picture concerns. It is not a list, however, likely to generate much political or press excitement. In this environment, it is an open question whether Chair Waters will take up any of the items on Representative McHenry's list.