SIFMA AMG, the Investment Company Institute ("ICI") and the Investment Adviser Association ("IAA") submitted the attached comments to the CFTC expressing concern with respect to the incomplete implementation of the protections provided to customer excess margin held by FCMs and DCOs under the "legal segregation with operational commingling" ("LSOC") model adopted by the CFTC. The groups have requested that the CFTC Division of Clearing and Risk delay the deadline for mandatory clearing by Category 2 entities until September 9, 2013 (the deadline for Category 3 entities), to allow DCOs and FCMs

FINRA is conducting job analysis surveys to inform updates to the Series 4, 9 and 10 qualification examinations. FINRA intends to gather information from currently registered individuals regarding their roles, responsibilities and job functions, and to use the information to update the related qualification examinations. See: Notice.

The CFTC filed a complaint against U.S. Bank for unlawfully using and holding Peregrine Financial Group's customer segregated funds. The complaint alleges that U.S. Bank unlawfully accepted Peregrine's customers' funds as security on loans it made, and that U.S. Bank improperly held Peregrine's customers' funds in an account which it treated as Peregrine's commercial checking account. See: Complaint: U.S. Bank, N.A. See also: CFTC Press Release.

The CFTC filed an amended complaint in its claim against various defendants accused of fraud. The emendation added allegations that the defendants lied to the CFTC about the fraud. See: Complaint See also: CFTC Press Release.

The CFTC met with SIFMA Asset Management Group regarding cross-border issues. See: Press Release.