SIFMA submitted a letter in response to the SEC's revised request for comments regarding Exchange Act Rule 15c2-12. SIFMA expressed its concern about what it considers to be "gross inaccuracies" in the Current Notice and the Original Notice of the SEC's time estimates for compliance with the rule. In addition, SIFMA noted what it characterized as the "failure of the SEC to estimate the [r]ule's primary disclosure compliance burdens, as separate and distinct from its secondary market compliance burdens." See : SIFMA Comment Letter. See also: MSRB Urges SEC to Revisit Municipal Securities Market

The SEC issued a notice soliciting comments about the extension of information collected from investment advisers under Advisers Act Rule 206(3)-2 ("Agency Cross Transactions for Advisory Clients"). Rule 206(3)-2 applies to all SEC-registered investment advisers, and permits them to comply with Section 206(3) of the Advisers Act by obtaining a client's blanket consent to enter into agency cross-transactions. In relying on the rule, investment advisers must provide certain disclosures to their clients. SEC-registered advisers must maintain and preserve certain information that is required under

The SEC issued a notice soliciting comments about the extension of information collected from funds under Investment Company Act Rule 12d1-1 ("Exemptions for Investments in Money Market Funds"). Under Investment Company Act Section 12(d), an investment company ("fund") generally is limited in the amount of securities that it may acquire from another fund. Rule 12d1-1 provides an exemption from these limitations for "cash sweep" arrangements, in which a fund invests all or a portion of its available cash in a money market fund ("MMF") rather than directly in short-term instruments. Rule 12d1-1

The Washington State Securities Division issued a statement of inquiry indicating its plan to propose rules to preserve the filing requirements for offerings of securities made under Tier 2 of the SEC's newly adopted rules for Regulation A offerings. The SEC's new rules adopt a definition of "qualified purchaser" that extends to "any person to whom securities are offered or sold" in offerings of up to $50 million in a Tier 2 offering under federal Regulation A. According to the Washington State Securities Division, "while the effect of defining a 'qualified purchaser' in this manner is to

MFA submitted comments in response to the CFTC's reopened comment period regarding the proposed rulemaking on position limits for derivatives. The CFTC reopened the comment period to provide commenters with the opportunity to discuss (i) issues addressed at the CFTC Energy and Environmental Markets Committee ("EEMAC") meeting held on February 26, 2015, and (ii) the new provisions in Table 11a of the position limits proposal, which shows counts of unique persons over certain percentages of the proposed position limit levels based on counts from January 2013 to December 2014. MFA raised concerns