FINRA addressed several trade reporting issues in connection with reporting transactions in TRACE-eligible securities to the Trade Reporting and Compliance Engine ("TRACE") system. FINRA addressed the following topics: Split-volume reporting; Reporting investment adviser-directed transactions; Reporting Securities Act Regulation S transactions; Transfers establishing the underwriting syndicate; Firm commitments prior to final pricing; Transfers facilitating settlement; and Reporting collateralized mortgage obligations. See: FINRA Trade Reporting Notice.

SIFMA's Compliance and Regulatory Policy Committee submitted comments on FINRA's proposal to adopt new FINRA Rules 3110 and 3120, which would replace NASD Rule 3010 ("Supervision") and Rule 3012 ("Supervisory Control System"), respectively. Comments by SIFMA included: That the requirements in proposed FIRNA Rule 3110(b)(6)(D) and proposed FINRA Rule 3110(c)(3)(A) that members establish procedures to prevent "standards of supervision" and "inspection standards," respectively, from being "reduced in any manner due to conflicts of interest that may be present" be modified to make it clear that

SIFMA sent a letter to the SEC to request a review of the regulatory structure of broker-dealers, exchanges, and the SRO model. SIFMA Executive Vice-President Randy Snook acknowledged that the current SRO structure "is widely viewed to be outdated and in need of reform." In its letter, SIFMA suggested the following key areas it believes the SEC should consider during its review: What is an exchange and why is it an SRO?; Examine the competition between exchanges and the broker-dealers they regulate; Competitive and regulatory disparities; and Funding of self-regulation Lofchie Comment: The

The SEC announced that Kathleen Weiss Hanley, Deputy Chief Economist and Deputy Director of the Division of Economic and Risk Analysis, is leaving the agency. Dr. Hanley will join the faculty at the University of Maryland's Robert H. Smith School of Business. See: SEC Press Release.

SIFMA and 14 other trade organizations, including the ABA, FSR, MBA, and ICI, submitted a joint comment letter to the U.S. House. The letter urged support for an amendment to H.R. 2610 (the "Transportation and HUD Appropriations Act for Fiscal Year 2014") to prohibit the FHA from insuring residential mortgages seized through eminent domain. The organizations stated that an amendment is necessary because numerous communities across the country are now considering using a municipality's eminent domain power to acquire performing but underwater mortgage loans held in private-label mortgage-backed