The SEC unanimously proposed new rules to require certain key market participants to have in place comprehensive policies and procedures surrounding their technology. The SEC's proposal, which is called "Regulation SCI," would replace the current voluntary compliance program with rules whose violation may be the subject of enforcement actions. SROs, certain alternative trading systems, plan processors, and certain exempt clearing agencies would be required to design, develop, test, maintain, and survey their key systems. The proposed rules would require them to ensure that their core

SEC Director of the Division of Investment Management ("IM"), Norm Champ, prepared (although did not directly deliver) a keynote address summarizing the short and long-term regulatory priorities of IM. Director Champ focused on discretionary rulemaking initiatives. The short-term priorities that Champ noted included: (1) developing recommendations for structural reform of money market funds; (2) finalizing identity theft and red flags rules first proposed by the SEC and CFTC in February 2012 to protect mutual fund investors and clients of asset managers; and (3) exploring methods to engage the

Undersecretary for Terrorism and Financial Intelligence, David Cohen, testified before the Senate Committee on Banking, Housing and Urban Affairs regarding anti-money laundering ("AML") and counter-terrorist financing regulations ("CFT"). In his testimony, Cohen expressed his belief that the current AML/CFT regime within the U.S. is one of the strongest in the world. Cohen described how the Treasury's Financial Crimes Enforcement Network ("FinCEN"), which implements the Bank Secrecy Act ("BSA"), is the backbone of the U.S. fight against money laundering. He also described the modernization of

SIFMA submitted the attached comments to the SEC regarding a proposed rule change filed by the Chicago Board Options Exchange ("CBOE"). SIFMA supported CBOE's proposal to permit the minimum price variation for mini-options to be the same as is permitted for standard options on the same underlying security. Click hereto view comment letter in full (links externally to SIFMA website).

ICI filed an emergency motion seeking expedited consideration of its appeal of a federal district court's decision upholding CFTC amendments to Rule 4.5, which require advisers to certain SEC-registered investment companies ("RICs") to (a) register as CPOs by December 12, 2012 and (b) comply with various regulatory requirements within 60 days after the effective date of a "harmonization" rule that has yet to be issued. The three court filings attached represent the emergency motion, the CFTC's opposition to the motion, and ICI's reply. See: ICI v. CFTC - Emergency Motion See also: Response in