The NFA has submitted to the CFTC proposed technical amendments to NFA Compliance Rule 2-7, Registration Rules 201, 203 and 501, and the Interpretive Notice to Registration Rule 402 regarding CTAs trading primarily in securities. The proposed amendments have to do largely with issues of terminology. Pursuant to the "ten-day" provision of CEA Section 17(j), the NFA will make these proposals effective ten days after receipt of submission, unless the CFTC decides to review the proposals for approval. View letter in full here (links externally to NFA website).

The International Organization of Securities Commissions ("IOSCO") published its final report of guiding principles for managing liquidity risk in a collective investment scheme ("CIS"). The report suggests ways in which a CIS can create, implement and monitor liquidity policies to ensure that the CIS meets its general redemption obligations. Specifically, the report makes the following recommendations: When creating a new CIS, its sponsor must be able to demonstrate to its regulator that it can comply with applicable local liquidity rules (if they exist); Where the CIS intends to invest in a

FINRA announced that it has fined Ameriprise Financial Services, Inc. and its affiliated clearing firm $750,000 for failing to have reasonable supervisory systems in place to monitor wire transfer requests and the transmittal of customer funds to third-party accounts. FINRA found that the firms did not have policies and procedures to detect multiple transmittals of funds going to third-party accounts, and did not adequately track previously rejected wire transfer requests. In addition, the firms failed to detect a former Ameriprise registered representative's misconduct despite numerous

Comptroller of the Currency Thomas J. Curry gave a speech at the Institute of International Bankers' Annual Washington Conference discussing the increasing attention that the OCC has paid recently toward operational risk in large banks, including with respect to debt collection practices, trading operations, the Bank Secrecy Act ("BSA") and Anti-Money Laundering ("AML") compliance, and mortgage servicing. In particular, Comptroller Curry highlighted the operational risk that arises from a failure to maintain adequate BSA and AML compliance programs. By way of example, Comptroller Curry cited

FINRA Rule 4524 (Supplemental FOCUS Information) requires each firm to file additional financial or operational schedules or reports. The SEC has approved the adoption of a supplemental schedule for derivatives and other off-balance sheet items ("OBS") that applies to carrying or clearing firms. Th e initial OBS disclosing a carrying or clearing firm's off balance sheet information, as of June 30, 2013, must be filed with FINRA on or before July 31, 2013. The OBS can be found in the regulatory notice attached below. Implementation Date: The initial supplemental schedule disclosing off-balance