SIFMA published comments that it submitted to the SEC on an NYSE proposed rule change to amend Rule 451, Transmission of Proxy Material. SIFMA stated that it supports the proposal to establish a 99 cent "success fee" to encourage the development of Enhanced Broker Internet Platforms, (EBIPs). Much of the letter focused on the timing of implementation. Click here to view letter in full (links externally to SIFMA website).

ICE released an exchange notice reminding members of Rules 2.28 and 2.34. Rule 2.28 requires member firms to immediately notify the Exchange in the event of a material adverse change in financial condition, defined as a 20% or more reduction in net capital or tentative net capital if the firm is a Futures Commission Merchant (FCM) or Introducing Broker. Rule 2.34 requires FCMs and Clearing Members to submit an audited financial statement to the exchange within 90 days of the close of the firm's fiscal year, or 60 days if the FCM is also a registered broker dealer. Click here to view notice in

CFTC Commissioner Bart Chilton spoke at the National Grain and Feed Association's Conference, continuing his campaign against passive investment funds and high-frequency traders, while again asserting that the CFTC should have the power to impose higher penalties. Below are the Commissioner's main points and suggested remedies: Commissioner Chilton argued that the record price of oil in the summer of 2008 was caused by speculation by "Massive Passives," large pools of managed money that invest in commodities in a passive manner. Chilton claims that large positions by such large funds can

Richard Berner, Director of the Office of Financial Research (OFR), testified before the House Financial Services Subcommittee on Oversight and Investigations regarding the OFR's recent activities and its role in supporting the Financial Stability Oversight Council (FSOC). In surveying the OFR's activities, Director Berner stated that the OFR has made "significant progress" in fulfilling its data and research responsibilities. Additionally, Director Berner outlined steps that the OFR has taken to address the concerns raised by the GAO in its September 2012 report, including by improving

Non-U.S. banks are reminded that the deadline for requesting the right to submit a "tailored" resolution plan is April 5, 2013.While the resolution plan (or "living will") itself is not due until December 31, 2013, non-U.S. banks that fail to submit a request for tailored plan status by the April 5th deadline must submit a comprehensive living will in December. The living will requirement applies to any non-U.S. bank with global assets of $50 billion or more that maintains a branch, agency office, or FDIC-insured bank subsidiary in the U.S. (referred to as "foreign banking organizations" or