SIFMA submitted comments to the MSRB on a draft proposal for MSRB Rule G-42 regarding the standards of conduct and duties of municipal advisors when engaging in municipal advisory activities other than the undertaking of solicitations. According to the letter, SIFMA supports the MSRB's efforts to develop a framework for the regulation of municipal advisors; however, SIFMA stated that it is concerned about certain aspects of the proposed rule, including that: the rule would improperly impose a fiduciary duty on municipal advisors providing advice to obligated persons; the proposed blanket

SIFMA, the Futures Industry Association ("FIA") and the Financial Services Roundtable ("FSR") (collectively, the "Associations") submitted comments to the CFTC on its staff advisory issued on November 14, 2013. The comments concern the applicability of CFTC rules to activity within the U.S. of CFTC-registered swap dealers ("SDs") and major swap participants ("MSPs") that are outside the U.S. The Associations stated that they are greatly concerned by the CFTC's introduction of a personnel-based test to the cross-border application of its swaps rules, and that they believe that the CFTC has

SIFMA submitted comments to the SEC, on the SEC's draft of the "Strategic Plan: Fiscal Years 2014-2018," to provide input for achieving some of the goals outlined in the draft plan as well as identify issues "critical to SIFMA members that fall within one or more of the SEC's strategic goals and underlying objectives." SIFMA suggested that the draft plan should address: implementing a uniform fiduciary standard; looking at qualitative factors in addition to quantitative factors and economic impacts in cost-benefit analyses; and coordinating the SEC's Section 913 efforts with the Department of

IOSCO published a consultation report titled "A Comparison and Analysis of Prudential Standards in the Securities Sector," which contains a comparative analysis of the key prudential/capital frameworks for securities firms. The two primary goals of the report were (i) to undertake a high-level comparative analysis of the key prudential/capital frameworks for securities firms for the purposes of highlighting similarities, differences and gaps; and (ii) to reach conclusions about key themes and issues identified in the comparative analysis and to use them to perform a high-level conceptual

The North American Securities Administrators Association ("NASAA") announced that its members have voted to approve a streamlined multistate review protocol to ease regulatory compliance costs on small companies attempting to raise capital under the JOBS Act.