The Clearing Firms Committee of SIFMA submitted comments to the SEC on FINRA's proposed rule change to NASD Rule 2340 ("Customer Account Statements"), which relates to estimated values of unlisted Direct Participation Programs ("DPPs") and Real Estate Investment Trusts ("REITs") on customer account statements. SIFMA stated that while it supports FINRA's efforts to design rules intended to improve customer protection and provide greater transparency in this area, it cannot support approval of the Proposed Rule Change for the same reasons as had been described in SIFMA's previous two comment

IOSCO published a report titled, "Risk Identification and Assessment Methodologies for Securities Regulators," which provides an overview of the methods, approaches, and tools that IOSCO and securities regulators have developed and implemented to identify and assess emerging and potential systemic risks. The report was prepared as part of the IOSCO Committee on Emerging Risks' effort to identify, analyze, and monitor systemic risk. The paper is organized around the following themes: the definition of risk; IOSCO risk identification methods; risk identification methods used by securities

The IRS issued a new Qualified Intermediary Agreement as a last-minute "gift" to banks and other withholding agents prior to the July 1, 2014 implementation of FATCA. The changes in Revenue Procedure 2014-39 reflect the enactment of the Foreign Account Tax Compliance Act ("FATCA") and the related regulations under chapters 3, 4 and 61 and Section 3406 of the Internal Revenue Code, the IRS said. Rev. Proc. 2014-39 updates and supersedes the prior Qualified Intermediary Agreement published in Rev. Proc. 2000-12 with respect to requirements of a qualified intermediary that apply on or after June

New SRO rules and rule proposals were announced by the SEC. Independent Consultant Shannon Fitzgerald Comment: EDGX Exchange, Inc. ("EDGX") has filed a proposed rule change to add a new order type called the Mid-Point Discretionary Order ("MDO") and to reflect the priority of such MDOs. The proposed rule change was published for comment in the Federal Register on March 25, 2014, but the U.S. Securities and Exchange Commission (the "Commission") has not received any comment letters to date.The Commission has now instituted proceedings to determine whether the proposed rule change should be

FINRA issued a regulatory notice to alert firms and associated persons of FINRA Rule 5250 ("Payments for Market Making"), which prohibits accepting payments for market making. Also, FINRA announced a new requirement under Rule 6432 ("Compliance with the Information Requirements of SEA Rule 15c2-11"). FINRA reminded firms that accepting monetary compensation or receiving shares of stock in connection with publishing a quotation, including filing of a Form 211, is prohibited pursuant to Rule 5250. In order to emphasize the prohibition, FINRA announced it adopted an additional certification under