The MSRB filed proposed amendments that would allow underwriters to satisfy certain submission requirements on disclosures in connection with primary offerings by their submission of data to the New Issue Information Dissemination Service ("NIIDS"). In addition, the proposed amendments would accomplish the following: revise deadlines for the submission of data to NIIDS, remove certain exceptions from the NIIDS submission requirements under Rule G-34 for certain short-term instruments, modify the Electronic Municipal Market Access (EMMA) system to include certain elements of the NIIDS data on

The North American Securities Administrators Association ("NASAA") began soliciting responses to its annual enforcement survey in March 2012. This year, 48 U.S. NASAA members responded to the survey request, a response rate of 94 percent. NASAA reported a significant increase in enforcement actions against investment adviser firms last year and a sharp rise in prison time for securities law violators. According to the survey, the number of enforcement actions involving investment adviser firms nearly doubled to 399 in 2011, and accounted for 15 percent of all enforcement actions handled by

The CFTC is proposing to adopt new regulations and amend existing regulations to require enhanced customer protections, risk management programs, internal monitoring and controls, capital and liquidity standards, customer disclosures, and auditing and examination programs for futures commission merchants (FCMs). The proposal also addresses certain related issues concerning derivatives clearing organizations (DCOs) and chief compliance officers (CCOs). The CFTC's summary of the high points of the rule changes are listed below: • Amending Part 30 of the regulations to require FCMs to hold

The CFTC issued an Order filing and settling charges that a futures commission merchant (an "FCM") violated CFTC regulation 166.3 by failing to diligently supervise its employees' handling of customer accounts. In particular, the firm failed to stop one of its customers from acting as an FCM through its customer account for third parties. Lofchie Comment: Pages 4-5 of the case provide a useful bibliography of "failure to supervise" actions brought under the CEA. Cross-Reference(s): CFTC Rule 166.3 [Customer Protection Rules; Supervision]. View Order in full here (links externally to CFTC

The SEC is adopting new Rule 17Ad-22 in accordance with Section 17A of the Exchange Act, Section 763 of Title VII ("Title VII") of the Dodd-Frank Act, and Section 805 of Title VIII ("Title VIII") of the Dodd-Frank Act. Rule 17Ad-22 establishes minimum requirements regarding how registered clearing agencies must maintain effective risk management procedures and controls, as well as meet the statutory requirements under the Exchange Act on an ongoing basis. The rule is NOT limited to firms that clear security-based swaps ("swaps"); it applies to all SEC-registered clearing agencies, although