The SEC solicited comment on a FINRA proposal to create a separate rule set that would apply to firms that meet the definition of "capital acquisition broker" and elect to be governed under this rule set. The proposed rule change was published in the Federal Register. Comments on the proposal must be submitted by January 13, 2016.

The CFTC amended Rule 1.35(a) ("Records of Commodity Interest and Related Cash or Forward Transactions") to reduce certain recordkeeping requirements imposed on end-users. The action was published in the Federal Register. In general, the amendments codify existing no-action relief provided by the CFTC staff. The effective date is December 24, 2015. Additional comments on the amended recordkeeping requirements may be submitted until February 22, 2016.

The SEC settled an insider trading case against a former employee of a credit card company. The settlement accepted by the district court alleged that the employee traded on misappropriated inside information illegally obtained from his employer. The defendant agreed to pay $4.7 million in disgorgement, prejudgment interest and civil monetary penalties.

The CFTC proposed amendments to system safeguards rules for designated contract markets ("DCMs"), swap execution facilities ("SEFs"), swap data repositories ("SDRs") and derivatives clearing organizations ("DCOs"). The proposed amendments affect existing provisions relating to system safeguards risk analysis and oversight and cybersecurity testing, and add provisions concerning certain aspects of security testing. The CFTC also requested comment on potential testing requirements for independent contractors. The proposal and the request for comment were published in the Federal Register. The

FINRA proposed expanding the instructions to the Derivatives and Other Off-Balance Sheet Items Schedule ("OBS") pursuant to FINRA Rule 4524 ("Supplemental FOCUS Information"). The proposed instructions include certain non-carrying/non-clearing firms that have significant amounts of off-balance sheet obligations. FINRA noted "considerable principal trading activities" of certain non-clearing firms during an examination of firms' margining practices in "extended settlement" transactions (including TBA transactions). FINRA stated that it is concerned about firms appropriately monitoring their