SIFMA submitted comments to FINRA regarding a proposal to amend the Order Audit Trail System ("OATS") rules. The proposed rules require members to identify non-member broker-dealers when reporting orders received by them and requires Alternative Trading Systems ("ATSs") to provide FINRA with order book information using additional OATS interfaces. SIFMA stated that it supports FINRA's goal: to enhance the automated surveillance and monitoring of trading activity on ATSs. However, according to SIFMA, the data collection requirements of the proposal would not serve FINRA's goal "because the

The IRS resumed its processing of requests for private letter rulings that concern the income of master limited partnerships ("MLPs") derived from minerals and other natural resources and whether such income constitutes "qualifying income" for purposes of determining if the MLP is a publicly traded partnership under section 7704 of the Internal Revenue Code. Previously in March 2014, the IRS issued a moratorium for such rulings, except for "down the middle" facts, pending a guidance project that involved engineers and would provide workable standards moving forward. At a meeting of tax

On March 6, 2015, the Financial Crimes Enforcement Network ("FinCEN") announced the assessment of a $10 million civil money penalty against Trump Taj Mahal Associates, LLC ("Trump Taj Mahal"), owner of the Trump Taj Mahal Casino Resort in Atlantic City, NJ, for the long-standing and repeated deficiencies in its anti-money laundering ("AML") compliance program. Trump Taj Mahal also will be required to undergo periodic external audits through 2019 and provide the results to its board of directors, as well as FinCEN and the Internal Revenue Service ("IRS"). The settlement, which was discovered

Acting Director of the SEC Division of Investment Management ("Division") Dave Grim delivered remarks at the PLI Investment Management Institute. He discussed the Division's priorities regarding data reporting, the use of derivatives by registered investment companies ("RICs") and liquidity requirements. Mr. Grim stated that the Division currently is reviewing its information-collection strategies in order to "enhance and modernize" data reporting to the SEC. He mentioned that the SEC is considering making updates to the basic census information requirements of Form N-SAR to reflect new market

SEC Commissioner Kara Stein discussed improving SEC rules to support innovation and facilitating capital formation. She delivered her remarks at the Stanford University Rock Center for Corporate Governance. Commissioner Stein asserted that part of the SEC's mission is to facilitate investment in innovative companies and "make venture funds' deployment of capital work as smoothly as possible." She also stated that the SEC is focused on new capital-raising methods, and must ensure its securities laws are flexible enough for a wide variety of companies and funding needs. Commissioner Stein