SIFMA submitted the attached fairly extensive comments to the Government Accountability Office ("GAO") on the GAO Study of Custody Rule Costs. The study is required by Dodd-Frank Section 412, and is intended to highlight the compliance costs that registered investment advisers incur to comply with Rule 206(4)-2 (the "Custody Rule") under the Advisers Act, as well as the costs which advisers might incur if the surprise-examination exemptions under the Custody Rule were eliminated. SIFMA stated that it is concerned that the application of certain provisions of the Custody Rule, under the

ICE Clear U.S. released a notice stating that clearing members should be aware the CFTC has granted an extension from November 8, 2012 to January 15, 2013 as the effective date to comply with the CFTC's Gross Customer Margin (GCM) requirement. As a result of the extension, the ICE Clear U.S. Platform release has also been delayed. The new implementation date has been scheduled tentatively for Saturday, January 12, 2012. View notice in full here (links externally to ICE website).

FINRA announced that it significantly increased transparency in the so-called "To-Be-Announced" (TBA) market for agency pass-through mortgage-backed securities. Through the Trade Reporting and Compliance Engine (TRACE), FINRA has begun disseminating TBA transaction information, including, but not limited to, (i) the CUSIP, (ii) the time of transaction, (iii) the price, and (iv) the size. In addition to the TBA market, the SEC has approved a FINRA proposal to publicly disseminate transaction information in agency pass-through mortgage-backed securities traded "specified." Click here to view

Amendments to NFA Financial Requirements Section 13, which codified NFA's requirement that FDMs file monthly operational and risk management reports and quarterly reports containing CFTC-required performance disclosures, became effective. The amendments also provide that any of these reports which are filed after their due date must be accompanied by a fee of $200 for each business day the report is late. The first monthly operational and risk management report, and the first quarterly report, were due on October 23, 2012. Reports filed after this due date must be accompanied by a fee of $200

CFTC Commissioner Bart Chilton delivered a speech before SEFCON (Swaps Execution Facilities Conference) in New York, New York. The SEF challenge is unlike anything the CFTC has done before, according to Chilton. Prior to Dodd-Frank, the CFTC did not have a system making the platforms registered entities, with concomitant regulatory responsibilities. In his speech, Chilton first addressed the need to have the most up-to-date technologies in the markets for both the industry and regulators. He argues that what is being done today is unacceptable. Chilton then discussed the lack of preparedness