FINRA filed with the SEC a proposal to adopt new FINRA Rule 2242 to address conflicts of interest relating to the publication and distribution of debt research reports. As anticipated, the proposed debt research rule is based on FINRA's existing equity research rule (NASD Rule 2711), but contains important modifications that FINRA considers necessary to reflect the differences between the equity and debt markets. First, the proposed debt research rule would adopt a "tiered approach" that distinguishes between debt research distributed to retail investors on the one hand, and institutional

FINRA filed with the SEC a proposed rule change to adopt, with modifications, NASD Rule 2711 ("Research Analysts and Research Reports") into the FINRA Rulebook and amend NASDRule 1050 ("Registration of Research Analysts") to create an exception from the research analyst qualification requirement. FINRA proposed to incorporate NASD Rule 2711 into new FINRA Rule 2241 with the following: minor changes to the definition of "investment banking services" to clarify that such services include all acts in furtherance of a public or private offering on behalf of an issuer; clarification of the

The CFTC-proposed amendments to the Residual Interest Deadline in CFTC Rule 1.22 ("Use of Futures Customer Funds Restricted") was published in the Federal Register. The amendment would remove the December 31, 2018 termination date from the phased-in compliance schedule for futures commission merchants ("FCMs") and provide assurance that the Residual Interest Deadline would be revised only through a separate CFTC rulemaking. Comments on the proposal must be submitted by January 13, 2015. See: 79 FR 68148; Fact Sheet; Q&A. Related news: CFTC Approves Rule Proposals and Product Interpretation

The CFTC-proposed amendments to CFTC Rule 1.35(a) ("Records of Commodity Interest and Related Cash or Forward Transactions") regarding records of commodity interest and related cash or forward transactions was published in the Federal Register. The CFTC proposed to require that all records maintained pursuant to CFTC Rule 1.35(a) must be searchable. The proposal also would clarify that all records must be kept in a form and manner that allows for identification of a particular transaction. The exceptions to this are records of oral and written communications leading to the execution of a

The CFTC Divisions of Swap Dealer and Intermediary Oversight ("DSIO"), Clearing and Risk, and Market Oversight issued a time-limited no-action letter (CFTC Letter No. 14-140) that extends relief to CFTC-registered swap dealers ("SDs") that are established under the laws of jurisdictions other than the United States ("Non-U.S. SDs") from certain transaction-level requirements under the CEA. The time-limited relief initially was provided in CFTC Letter No. 14-74. On November 14, 2013, DSIO issued an Advisory ("DSIO Advisory") in response to inquiries from swap market participants regarding the