The Asset Management Group of SIFMA ("SIFMA AMG") submitted comments to the CFTC renewing a January 13th request for no-action relief as to the CFTC's compliance date for mandatory trading on SEFs. In response to the CFTC's request for an explanation as to why SEF trading should not be made mandatory, the trade association listed 17 major issues, some of which were both operational and legal (see pages 2-4 of the letter). Lofchie Comment: Craig Pirrong (also known as the Streetwise Professor) describes the mandate for firms to trade on Swap Execution Facilities as the worst provision in Dodd

SIFMA and the Association for Financial Markets in Europe ("AFME") issued a joint public statement regarding the Transatlantic Trade and Investment Partnership negotiations, remarking that "expanding opportunities for financial services providers and their clients in the transatlantic market can only be realized if TTIP includes commitments for regulatory coordination and cooperation." The associations further noted that the week's TTIP meeting offered a critical opportunity to improve the efficiency of regulations across jurisdictions, which each believed would "facilitate and guide efforts

The SEC issued a no-action letter under section 17(e)(1) of the Investment Company Act permitting an affiliate of Nuveen Investment Funds, Inc., an SEC-registered investment company, to act as securities lending agent for certain series of the fund (the "Lending Funds"). The letter permitted the affiliated lending agent to negotiate rebate rates on behalf of the Lending Funds in accordance with guidelines adopted by the lending agent. See: SEC No-Action Relief to U.S. Bank National Association.

The SEC issued no-action relief to a German asset management company, MEAG MUNICH ERGO AssetManagement GmbH ("MEAG"), stating that the SEC would not take action if MEAG does not register with the SEC as an investment adviser under Advisers Act Section 203(a) ("Registration of Investment Advisers"). According to MEAG's incoming letter, it is not engaged in the business of "advising others," and only performs asset management and investment advisory services for companies that are wholly owned subsidiaries of MEAG's parent company. Lofchie Comment: It is not particularly clear why the staff

The MSRB requested public comment on a proposal to establish, for the first time, explicit requirements for municipal securities dealers to seek the most favorable price possible when executing transactions for retail investors. According to the MSRB, if approved, the proposed "best-execution" standard would "provide benefits for investors, promote competition among dealers and enhance market efficiency." The proposed rule, which was modeled after FINRA's best-execution rule for the equity and corporate fixed income markets, would require municipal securities dealers to seek to obtain for