FINRA announced that it has ordered a broker-dealer to pay more than $10.7 million in restitution to customers who placed mutual fund orders with the firm via paper orders from retail customers and who received an inferior price for their shares as a result of the firm's delay in submitting purchase orders. FINRA also fined the firm for its alleged pricing errors and for failing to have an adequate supervisory system and written procedures in this area. The order does not assert that the delay was intended to defraud customers. Click here to view FINRA notice in full (links externally to FINRA

A FATCA Intergovernmental Agreement ("IGA") between the U.S. and Ireland was signed in Dublin on December 21. As previously announced, the IGA is based on the Model I reciprocal version issued by the U.S. Treasury Department in July. The text of the main agreement of the Irish IGA is virtually identical to the IGA signed by the United Kingdom, including a "most favored nation" clause under which the U.S. agrees to extend to Ireland any additional exemptions or provisions that are subsequently provided in IGAs with other countries. Annex II, which contains a list of exempt and deemed compliant

In a statement dated December 26, Commissioner Chilton asserted that, in light of this year's MF Global and Perregrine failures, there should be a futures insurance fund for customers of failed FCMs. Click here to view statement in full (links externally to CFTC website).

The SEC issued an Investor Bulletin to help the purchasers of municipal bonds better assess the bonds' credit risks. The bulletin provides several factors for investors to consider, including: (i) the type of bond, (ii) the purpose and nature of the financing, (iii) the overall financial condition of the issuer, and (iv) the sources of funds to pay both principal and interest. Lofchie Comment: Cadwalader is sponsoring a conference on distressed municipalities focusing particularly on the City of Detroit. Information on the conference may be found by going to the Cabinet home page and looking

SIFMA submitted the attached comments regarding interim final rules promulgated by the SEC temporarily exempting uncleared security-based swaps ("SBS") entered into between eligible contract participants (as defined in CEA Section 1a(18)) from certain provisions of the Securities Act, the Exchange Act, and the Trust Indenture Act. This letter supplements the letter submitted jointly with ISDA on April 20, 2012, wherein SIFMA urged that the SEC permanently exempt SBS transactions involving eligible contract participants from the registration requirements of Section 5 of the Securities Act. This