The Managed Funds Association ("MFA") submitted additional comments to the SEC to supplement two previous MFA letters regarding the proposed imposition of a capital charge on security-based swap dealers ("SBSDs") when their financial end user counterparties elect to segregate initial margin for uncleared security-based swaps. The letter specified that the MFA is writing "to highlight the protections and safeguards afforded both the SBSDs and the pledgors by tri-party segregation arrangements." The letter included a list of suggested contractual provisions that would be protective of the SBSD

FINRA filed Amendment No. 1 with the SEC in response to comments it received regarding the proposed rule involving TRACE reporting for asset-backed securities ("ABS"). In the amendment, FINRA proposes to revise FINRA Rule 6750 ("Dissemination of Transaction Information") to include ABS among TRACE-Eligible Securities that FINRA will disseminate publicly.The amendment also proposes to revise certain existing definitions in FINRA's rules and add new definitions in order to delineate the specific ABS that would be subject to dissemination pursuant to Rule 6750. Specifically, FINRA has proposed to

The SEC approved a joint industry plan from participating SROs and Exchanges including FINRA, NYSE, BATS-Y Exchange, and Nasdaq, governing the process of selecting a plan processor and developing a plan for the consolidated audit trail ("CAT"). The 19 SROs and Exchanges (the "Participants") collectively filed a plan on September 3, 2013, to create, implement and maintain a CAT with respect to the trading of NMS securities that would capture customer and order event information for orders in NMS securities across all markets. The rule was filed pursuant to Exchange Act Section 11A ("National

The SEC approved on an accelerated basis the new MSRB Rule G-45 ("Reporting of Information on Municipal Fund Securities") in order to collect comprehensive data from the underwriters of 529 college savings plans, as well as amendments to MSRB Rules G-8 ("Books and Records to Be Made by Brokers, Dealers and Municipal Securities Dealers") and G-9 ("Preservation of Records"). MSRB Rule G-45 requires 529 plan underwriters to submit new information to the MSRB electronically, including information regarding the plan's assets, contributions, withdrawals, fee and cost structure, and performance. The

The SEC Division of Investment Management ("staff") issued a Guidance Update in order to ensure consistent application of the "Unbundling Rule" regarding amendments to investment company charters pursuant to Exchange Act Rule 14a-4 ("Requirements as to Proxy"). The Guidance stated that Exchange Act Rule 14a-4(a)(3) and Exchange Act Rule 14a-4(b)(1), together known as the "unbundling rule," are intended to provide a means for shareholders to communicate their views to the board of directors on each matter to be acted upon. Furthermore, the Guidance reiterated the SEC's position that a matter