FINRA requested comments on a concept proposal to develop a new Comprehensive Automated Risk Data System ("CARDS"). CARDS would be a rule-based program that would allow FINRA to collect on a standardized, automated and regular basis, account information, as well as account activity and security identification information that a firm maintains as part of its books and records. Lofchie Comment: This looks like a significant technology build and expansion of regulatory reach (described in the proposals as "a broad ranging initiative supporting a comprehensive approach to supervising firms"). That

FINRA released updates to the Interpretations of Financial and Operational Rules to reflect the recommendations that the SEC Division of Trading and Markets made to FINRA. The updated interpretations consist of specified additions, revisions and rescissions that relate to Exchange Act Rules 15c3-1 ("Net Capital Requirements for Brokers or Dealers"), 15c3-1b ("Adjustments to Net Worth and Aggregate Indebtedness for Certain Commodities Transactions (Appendix B to Rule 15c3-1)"), 15c3-1d("Satisfactory Subordination Agreements (Appendix D to Rule 15c3-1)"), 15c3-3 ("Customer Protection - Reserves

FINRA issued an Information Notice providing a schedule to assist firms and reduce the number of Federal Reserve Board Regulation T and Exchange Act Rule 15c3-3 ("Customer Protection - Reserves and Custody of Securities") extensions denied around the holidays. See: FINRA Information Notice and Schedule.

The Board of Governors of the Federal Reserve System ("FRB") invited public comment on proposed amendments to Regulation A ("Conditional Small Issues Exemption"). Regulation A amendments would implement Dodd-Frank Section 1101 ("Federal Reserve Act Amendments on Emergency Lending Authority"), which is designed to ensure that any emergency lending program or extension of credit authorized by the FRB is for the purpose of providing liquidity to the financial system, and not to aid an individual failing financial company. Comments must be submitted by March 7, 2014. See: FRB Request for Public

FINRA filed with the SEC a proposed rule change to amend FINRA Rule 2360 ("Options") as it relaets to certain index options. The rule amendment would specify that position limits for standardized equity options shall be the highest position limit established by an options exchange on which the option trades, which has the effect of eliminating position limits on standardized options on Standard and Poor's Depositary Receipts Trust ("SPY") and increasing the position limit for standardized options on iShares MSCI Emerging Markets Index Fund ("EEM") to 500,000 contracts. Additionally, the