The Asset Management Group of SIFMA ("SIFMA AMG") submitted comments to the SEC concerning its proposed rule on the application of certain Title VII requirements to security-based swap transactions. In the letter, SIFMA AMG recommended that the SEC not impose Title VII's customer protection requirements on transactions in which neither the dealer nor its counterparty is a U.S. person. SIFMA AMG argued that when asset managers execute security-based swap transactions with non-U.S. dealers on behalf of non-U.S. clients, the non-U.S. clients "do not expect U.S. customer protections to apply, nor

The NFA issued a notice to members requiring any commodity pool operator ("CPO") that files a claim of notice under CFTC No-Action Letter 14-112 (relating to the consolidation of financial statements) to notify the NFA on or before July 31, 2015. In order to complete the notification process with the NFA, the notice specified, CPOs first must ensure that all parent pools and related wholly owned subsidiaries have been properly identified in the Annual Questionnaire. CPOs should notify the NFA of each 14-112 No-Action claim notice by accessing the Exemption System available on the NFA's Web

FINRA's proposal to require each of its members' Web sites to include a readily apparent reference and hyperlink to BrokerCheck was published in the Federal Register. The proposal would amend FINRA Rule 2210 to require a member's Web site to provide a hyperlink to BrokerCheck on: (i) the initial Web page that the member intends to be viewed by retail investors and (ii) any other page that includes a professional profile of one or more registered persons who conduct business with retail investors. Comments on the proposal must be submitted by August 3, 2015. See: FINRA Rule 2210; 80 FR 40092

The Federal Register published the SEC's filing of the Twenty-Third Substantive Amendment to the Second Restatement of the Consolidated Tape Association Plan ("CTA Plan"). The Amendment establishes a fee that will be charged to a vendor or other data redistributor that fails to comply with the CTA Plan participants' consolidated volume requirements. See: 80 FR 39821; SEC Notice ; SEC Filing.

The SEC solicited comments on a proposed rule change by FINRA to amend Rule 7650A (Collection of Fees). The proposed rule would require FINRA members that are FINRA/Nasdaq Trade Reporting Facility participants to submit billing disputes within sixty days of receipt of the invoice to the FINRA/Nasdaq Trade Reporting Facility. Comments must be submitted prior to July 31, 2015. See: 80 FR 39818. Related News: FINRA Proposes Rule to Amend Debit Process for the Collection of Trade Reporting Facility Fees (Fed. Reg.) (July 7, 2015).