FINRA filed with the SEC proposed amendments to Rule 7710 relating to fees for the OTC Reporting Facility ("ORF"), as well as the deletion of Rule 7740 relating to historical research and administrative reports. These amendments concern the migration of the ORF to FINRA's Multi-Product Platform ("MPP"). FINRA's MPP is a platform owned by FINRA and developed by NASDAQ which consolidates FINRA's technology for gathering and disseminating trade execution and, where applicable, quotation data, conducting trade comparisons and gathering associated regulatory data for debt and equity securities

Linked below is the latest article in the Energy Metro Desk series, "Drums Along the Potomac," which analyzes the recent CFTC staff roundtable on position limits. The article reviews the discussion at the roundtable, noting that the position limits issue is at a crossroads, where the CFTC "is concerned that speculation is being done in the name of hedging, and industry is concerned that hedging will be compromised in the name of curbing speculation." According to the article, most people attending the meeting "seemed to agree that hard-and-fast position limit rules will likely reduce liquidity

The FINRA proposal relating to options exercise procedures was published in the Federal Register and is effective immediately. The proposed amendments to FINRA Rule 2360 ("Options") relate to expiring standardized equity options procedures. The amendment will harmonize the rules with those of the Options Clearing Corporation and other options exchanges. Specifically, the rule would change the expiration date for most standardized options contracts to the third Friday of the expiration month instead of the Saturday following the third Friday. While the rule change was deemed noncontroversial by

SIFMA submitted supplemental comments to FINRA on its concept proposal to develop the Comprehensive Automated Risk Data System ("CARDS"). SIFMA stated that its comments are intended to encourage FINRA to publicly address certain remaining issues with CARDS as it continues to consider the concept. In March 2014, SIFMA filed a comment letter that expressed a range of significant concerns with the CARDS concept. SIFMA urged FINRA to make public its cost-benefit analysis with respect to the CARDs rules. SIFMA urged FINRA to work with the SEC and other SROs to ensure that the new CARDS reporting

The SEC Divisions of Investment Management and Corporation Finance issued a staff bulletin regarding investment advisers' responsibilities in voting client proxies, retaining proxy advisory firms, and the requirements of exemptions to the federal proxy rules that are often relied upon by proxy advisory firms. The bulletin consists of a series of questions and answers pertaining to proxy voting, including the following: Is an investment adviser required to vote every proxy? What are some of the considerations that an investment adviser may wish to take into account if it retains a proxy