Dodd-Frank mandated that the GAO examine the impact of the permanent exemption on the quality of financial reporting by small public companies and on investors. According to the GAO, a majority of empirical studies suggests that compliance with the auditor attestation requirement has a positive impact on investor confidence in the quality of financial reports. Accordingly, the GAO recommends that the SEC consider requiring public companies to explicitly disclose whether the relevant company has obtained an auditor attestation of its internal controls. The SEC responded that investors could

The NFA has issued a $300,000 fine against Interactive Brokers ("Interactive"), a futures commission merchant, for, among other problems, violations of NFA Bylaw 1101. NFA Bylaw 1101 generally prohibits CFTC registrants from doing business with firms that should be, but are not, registered with the CFTC. In effect, it requires private firms to police each other's compliance with CFTC registration requirements. Mehta Comment: Relevance of this matter is an NFA Member's compliance with NFA Bylaw 1101 (i.e., prohibition on NFA Member from doing business with a non-NFA Member that is required to

The NFA released July 2013 revisions to the Financial Requirements Section 16 and the related interpretive notice regarding cleared swaps customer collateral accounts. These updates are available in five appendices of policies that include: Compliance with theExchange Act Rule 15c3-1: the calculation of haircut charges on securities; additionally, charges on the more common securities are reviewed: government securities and Canadian debt obligations, municipal securities, other municipal securities, money market funds, commercial paper, bankers' acceptances and certificates of deposit, non

Commissioner Gary Gensler announced the CFTC will hold a public meeting to consider Final Interpretative Guidance on Cross-Border Application of the CFTC and a Cross-Border Phase-In Exemptive Order. The meeting is scheduled for July 12, at 9:30 a.m. See: CFTC Public Meeting Announcement.

The Municipal Securities Rulemaking Board ("MSRB") submitted a very thoughtful comment letter in response to the SEC's proposed Regulation Systems Compliance and Integrity ("Regulation SCI"). While the MSRB stated its support for many aspects of the proposed rule, its many detailed comments also highlighted the difficulties inherent in the SEC's attempt to create such an ambitious regulatory scheme out of whole cloth. According to the MSRB, these difficulties include that Regulation SCI is overly broad, impractical and ambiguous. See: MSRB Comment Letter S7-01-13. See also: Cadwalader Memo