The SEC issued a no-action letter confirming that the quality of the relationship between an issuer and an investor is the most important factor in determining whether a substantive relationship exists between the two, and that such a relationship affects compliance with the general solicitation or general advertising requirements within the meaning of Rule 502(c) of Regulation D. In response to a request by an online venture capital firm that facilitates indirect investment by pre-qualified, accredited and sophisticated Members, the SEC stated that the policies and procedures, as detailed in

FINRA proposed a rule change with the SEC to adopt FINRA Rule 3210 (Accounts at Other Broker-Dealers and Financial Institutions) into the consolidated FINRA rulebook. FINRA also proposed to delete NASD Rule 3050 (Transactions for or by Associated Persons) as well as delete incorporated NYSE Rules 407 (Transactions – Employees of Members, Member Organizations and the Exchange) and 407A (Disclosure of All Member Accounts) as well as the related Incorporated NYSE Rule Interpretations 407/01 and 407/02 (Transactions – Employees of Member Organizations and the Exchange). The proposed rule (as well

Several Democratic Senators urged the Department of Labor ("DOL") to "ensure that rules related to retirement savings do not work at cross-purposes in a way that could limit investor access to education and increase costs for middle-class Americans." Senators Jon Tester (D-MT), Joe Donnelly (D-IN), Heidi Heitkamp (D-ND), and Angus King (D-ME) submitted the letter regarding DOL's proposed changes to the ERISA definition of "fiduciary." The Senators expressed their concern that "the rule in its current form could stifle access to meaningful investment advice for millions of Main Street investors

The CFTC announced the opportunity for public comment on the swap data recordkeeping and reporting requirements under Part 45 of the CFTC Rules (Swap Data Recordkeeping and Reporting Requirements) Comments must be submitted by October 6, 2015. See: 80 FR 47477: Notice of Intent To Renew Collection 3038-0096, Swap Data Recordkeeping and Reporting Requirements.

The SEC approved the amendments to FINRA rules that provide a Web-based delivery method for completing the Regulatory Element of the Continuing Education ("CE") requirements. The new Web-based delivery method, which will be called "CE Online" and administered through FINRA's CE Online System, will provide a registered person with the flexibility to complete the Regulatory Element at a location of their choosing at any time during the person's 120-day window for completion of the Regulatory Element. The amendments will become effective on October 1, 2015. See: FINRA Regulatory Notice 15-28