FINRA issued an information notice that includes the 2014 due dates for firm filings of Annual Audit, Financial and Operational Combined Uniform Single ("FOCUS") Reports, Form Custody, and FINRA-required supplemental FOCUS Report information, which includes a Supplemental Statement of Income ("SSOI") as well as Off-Balance Sheet ("OBS") Reports. According to the notice, all filings must be received by FINRA by their required due dates in order to avoid penalty fees and/or the suspension of a firm's FINRA membership. See: FINRA Information Notice.

FINRA filed a proposed rule change with the SEC to extend the expiration date of FINRA Rule 0180 ("Application of Rules to Security-Based Swaps") to February 11, 2015. FINRA Rule 0180 limits, with certain exceptions, the application of FINRA rules with respect to security-based swaps. Lofchie Comment: The extension indicates that the SEC is absorbing the lesson of the CFTC's difficulties in adopting a full set of rules that work. Perhaps under new leadership and with its recent request for comments on at least some of its interpretations, the CFTC will take the opportunity afforded by the

The CFTC published a request for comments regarding the Staff Advisory issued on November 14, 2013, in the Federal Register. The CFTC is soliciting comments regarding the activity in the United States of swap dealers ("SDs") and major swap participants ("MSPs") registered with the CFTC that are established in jurisdictions other than the United States, whether or not affiliates of a U.S. person, a "non-U.S. SD" or "non-U.S. MSP." Comments are due on March 10, 2014. See: 79 FR 1347. Related News: CFTC Issues Advisory on Applicability of Transaction-Level Requirements in Certain Cross-Border

The Office of the Comptroller of the Currency ("OCC") has announced a civil money penalty against JPMorgan Chase for AML violations, including failure to report suspicions about Bernard L. Madoff Investment Securities, LLC to U.S. law enforcement and regulators. See: OCC Press Release.

SIFMA submitted comments to the SEC regarding a rule proposed by the New York Stock Exchange, LLC ("NYSE") to establish an institutional liquidity program on a one-year pilot basis. Under the proposal, as a one-year pilot program, NYSE would add the new NYSE Rule 107D to establish an Institutional Liquidity Program ("ILP") to attract buying and selling interest to NYSE for NYSE-listed securities by facilitating interactions between institutional customers and providers of liquidity exceeding minimum size requirements. In the comment letter, SIFMA stated its support for competition in the