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Steven Lofchie Commentary by Steven Lofchie

FINRA's Office of the Chief Economist ("OCE") found that brokers that route orders to affiliated alternative trading systems ("ATSs") at high rates obtain lower fill rates. In a working paper, OCE analyzed order-handling information over the span of 330 million institutional orders to study whether order routing by brokers to affiliated ATSs impacts the quality of execution. FINRA's OCE found that trading costs are higher when clients select a broker with high rates of affiliated ATS routing. In addition, FINRA's OCE concluded that enhanced disclosures on order handling could benefit

Commentary by Nihal Patel

CFTC Chair J. Christopher Giancarlo will seek an extension (to March 15) of the comment period for a proposal to amend various aspects of the rules governing the trading of swaps (the "SEF Proposal"). He also intends to move forward with amendments to the CFTC cross-border framework. In a keynote address at the ABA Business Law Section Derivative & Futures Law Committee Meeting, Mr. Giancarlo highlighted aspects of the SEF Proposal and his approach to cross-border regulation. On cross-border matters, Mr. Giancarlo reiterated points he raised in a 2018 white paper, " Cross-Border Swaps

In its sixth annual report, the Consumer Financial Protection Bureau ("CFPB") Office of Servicemember Affairs analyzed complaints from servicemembers, veterans and their families (collectively, "servicemembers") regarding financial services or products. The CFPB stated that roughly 48,800 complaints from servicemembers were received during the reporting period, April 1, 2017 and August 31, 2018. The majority of complaints by servicemembers related to credit or consumer reporting and debt collection. These include, among others, incorrect information on credit reports that put security

ISDA recommended risk management best practices to ensure "greater consistency in risk practices at CCPs across the globe." In the Best Practices paper, ISDA recommends, among other things, that: risk management be consistent with the underlying risk of a particular product ( e.g., distinguishing products traded on a central order book from OTC-cleared products); CCPs have "robust membership requirements" ( i.e., financial and operational capability) that are reviewed consistently; products that are cleared by a CCP be adequately "standardized and liquid"; CCPs ensure that there is sufficient