FINRA filed a proposed rule change with the SEC to amend FINRA rules governing the reporting of certain securities transactions. The rule changes would amend FINRA's rules relating to over-the-counter ("OTC") transactions in equity securities to FINRA facilities, and orders in NMS stocks and OTC Equity Securities to the ORDER Audit Trail System ("OATS"). See: Text of Proposed Rule Change; FINRA Press Release.

CFTC Commissioner Bart Chilton spoke at the Ouachita Speakers Series regarding politics, business, technology and reasonable citizenship. Commissioner Chilton spoke about the financial sector, making it a point to say that the "malfeasance in the financial sector" cannot be solved by passing another law or regulation because government cannot regulate ethics or morals. Instead, he encouraged top executives and boards of directors to instill core values and reasonable responsibilities in their business structures and employees. He then emphasized that people must be adaptable to change and

In his November 10th blog post, economist Craig Pirrong discussed the new CFTC position limits proposal. His commentary, linked below, notes that the new proposal has more sensible aggregation standards and permits the set-off of futures positions against swaps. That said, he closes by observing that the proposed rule is "unbelievably long," amounting to 533 pages and 846 footnotes, with "land mines" throughout. Lofchie Comment: Professor Craig Pirrong economic analysis of Position Limits may be briefly summarized as follows: (i) better than the original proposal, but (ii) still pretty bad and

The U.S. Treasury Department has once again revised the Model Intergovernmental Agreements ("IGAs") and their Annexes under FATCA and posted the revised versions on their website. There are at least three substantive changes. First, the revised IGAs now provide that equity and debt interests in an Investment Entity are considered "regularly traded on an established securities market" (and thus exempt from FATCA reporting) only if there is a "meaningful" volume of trading with respect to the interests on an ongoing basis on an exchange that is officially recognized and supervised by a

According to an MFA Blog post and a Reuters news item, Volker Bouffier, the Hesse state premier in Germany as well as deputy party leader to Chancellor Angela Merkel, stated his reservations about a financial transaction tax ("FFT") that will be enacted in Germany. Mr. Bouffier expressed his doubt by stating that the FFT would be a "unilateral move that would have devastating consequences for financial centers" in Germany See: MFA Blog Post; Reuters News Article.