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The North American Securities Administrators Association ("NASAA") issued an advisory to inform investors of the very limited responsibilities of third-party custodians of self-directed individual retirement accounts ("IRAs") and other qualified plans. In short, the advisory warns that such custodians serve as administrators and do not act to protect investors from investment mistakes. See: NASAA Advisory.

The NFA issued a Notice to Members announcing that the NFA Interpretive Notice titled " NFA Compliance Rules 2-4 and 2-36: Prohibition on the Use of Certain Electronic Funding Mechanisms" was recently approved by the CFTC and will become effective on January 31, 2015. The Interpretive Notice prohibits NFA Members from permitting customers to fund their futures or forex accounts with a credit card or other electronic methods tied to a credit card, or a payment facilitator such as PayPal. See: NFA Notice I-14-33. Related news: NFA-Proposed Interpretive Notice Prohibiting the Use of Credit Cards

MFA submitted comments in response to the Financial Stability Board's ("FSB") consultative document titled " Cross-Border Recognition of Resolution Action" which was published on September 29, 2014. MFA voiced support for the adoption of statutory recognition frameworks in FSB member jurisdictions as the only appropriate solution to cross-border recognition resolution actions. Additionally, MFA urged the FSB to ensure: that the statutory recognition frameworks are crafted carefully and fairly to include all parties and provide no favorable treatment for different types of parties; and that it

FINRA released the first podcast in a three-part series on topics to consider when planning a Firm Element training, as identified in the CE Council's Fall 2014 Firm Element Advisory. The podcast reviews recently approved updates to FINRA rules, including: the "Communications with the Public" rule; amendments to FINRA's rule about transactions related to initial public offerings; a new FINRA rule prohibiting firms and their associated people from conditioning, or seeking to condition, a customer settlement on that customer consenting to expunge the dispute information from the Central

Bob Zwirb Steven Lofchie Commentary by Bob Zwirb and Steven Lofchie

The CFTC reopened the public comment period for its proposed position limits rule. According to the CFTC, the reopening of the comment period is in anticipation of questions and comments that may arise from the CFTC's Agricultural Advisory Committee meeting scheduled for December 9, 2014. CFTC Commissioner Sharon Bowen released a statement to express her support of the comment period reopening. She urged the CFTC to not allow the rule to "linger indefinitely" on the CFTC docket, stating that she believes a final rule should be released by spring 2015. The comment period will be open for 45