New rules and rule proposals from CBOE and NASDAQ. Click on the links to view the SEC notices for each rule change and proposal. CBOE: Order Granting Approval of a Proposed Rule Change to Increase Position and Exercise Limits for EEM Options NASDAQ: Proposed Rule - Establish Fees for New Optional Wireless Connectivity for Co-located Clients (See also: Exhibit 5)

The CFTC's open meeting scheduled for Thursday, October 25, 2012 has been cancelled. View press release in full here (links externally to CFTC website). See also: CFTC Open Meeting to Consider a Notice of Proposed Rulemaking on Enhancing Customer Protections (10/25).

SIFMA, the American Bankers Association ("ABA"), and the Financial Services Roundtable ("FSR") submitted a joint comment letter to multiple federal agencies on the capital treatment of TBA transactions in mortgage securities. View letter in full here (links externally to SIFMA website).

SEC Commissioner Daniel M. Gallagher delivered the keynote address at the National Society of Compliance Professionals National Meeting. The first part of the speech discussed the separate histories of the U.S. regulation of broker-dealers and that of investment advisers. At the conclusion of this section of his talk, he said that Dodd-Frank required the SEC to consider harmonizing the broker-dealer and investment adviser regulatory regime (especially with regard to fiduciary obligations), but it did not mandate such harmonization. Rather, the SEC would have to consider what, if any, rule

The plaintiffs argue that the court's decision for ISDA, and against the CFTC, in the position limits case had the effect of vacating certain amendments to the definition of "bona fide" hedging which are cross-referenced in CFTC Rule 4.5; thus, the CFTC cannot enforce the version of Rule 4.5 that relies upon the vacated amendments. See: Supplemental Memorandum: ICI and Chamber of Commerce v. CFTC (12-cv-00612). Related News Stories: ICI and U.S. Chamber of Commerce vs. CFTC (Challenging CFTC's Denial of Complete CPO Exemption for RICs) (with Materials) (with Lofchie Comment); ISDA v. CFTC