The Office of the Comptroller of the Currency ("OCC") and the Board of Governors of the Federal Reserve System ("FRB") have announced the issuance of several formal enforcement actions against JPMorgan Chase, N.A. and its bank holding company, JPMorgan Chase Co., in connection with the well-publicized derivatives losses previously suffered. In addition, JPMorgan Chase, N.A. and JPMorgan Chase Co. were the subject of enforcement actions requiring improvements to their AML procedures. See: FRB Press Release; OCC Issues Cease and Desist Order against JPMorgan Chase, N.A., Related to Derivatives

The CFTC has issued an order granting a request made by Ice Clear Credit LLC ("ICC"), a CFTC-registered derivatives clearing organization ("DCO"), pursuant to Section 4d(f) of the Commodity Exchange Act that is also registered with the SEC. The order sets forth terms and conditions under which ICC and its clearing members which are dually registered as futures commission merchants with the CFTC, and as broker-dealers with the SEC, may (1) hold credit default swaps ("CDS") and security-based CDS in a cleared swaps customer account subject to Section 4d(f) of the CEA; and (2) portfolio margin

The CFTC has announced the appointment of Melissa Jurgens to serve as the Secretary of the Commission. Ms. Jurgens will be responsible for managing the decisional workload of the CFTC as it continues Dodd-Frank rulemaking and implementation, as well as ongoing enforcement and no-action matters. Click hereto view announcement in full (links externally to CFTC website).

The Division of Trading and Markets has issued no-action relief stating that it will not recommend enforcement action under Exchange Act Rule 17a-8 ("Financial Recordkeeping and Reporting of Currency and Foreign Transactions") if a broker-dealer relies on a registered investment adviser to perform some or all of its customer identification program ("CIP") obligations. The letter extends a 2011 no-action position, which is substantially similar to previous no-action positions taken in 2004. Expiry Date: This letter extends the no-action position in the 2011 Letter for an additional 2 years from

NASAA has released for internal and public comment proposed changes to Model Rules 102(e)(1)-1 and 203(a)-2 under the Uniform Securities Act of 1956 and Model Rules USA 2002 411(c)-1 and USA 2002 411(f)-(1) under the Uniform Securities Act of 2002 to clarify requirements relating to inadvertent custody of client funds. The proposal is intended to harmonize recordkeeping requirements in the rules to provisions that establish when funds and securities that are inadvertently received are deemed to be in the possession of an adviser. Comments Due: February 12, 2013. Lofchie Comment: This proposal