Based on examinations of broker-dealers throughout the U.S., NASAA identified the top compliance violations, which included: failure to follow written supervisory policies and procedures, suitability, correspondence/e-mail, maintenance of customer account information, and internal audits. NASAA further offered a series of recommended best practices for broker-dealers to consider in order to improve their compliance practices and procedures. Best practice recommendations covered the following areas: Suitability; Developing, Updating, and Enforcing Written Supervisory Procedures; Exception

Rules changes from FINRA and NYSE Arca: FINRA: Proposed Rule - Amending the Customer and Industry Codes of Arbitration Procedure Relating to Subpoenas and to Arbitrator Authority to Direct the Appearance of Associated Person Witnesses and the Production of Documents without Subpoenas NYSE Arca: Effective Immediately - Amending the NYSE Arca Equities Schedule of Fees and Charges for Exchange Services to Eliminate the Tape A Step Up Tier, Modify the Remaining Tape Step-Up Tiers and Introduce an Alternative Method of Qualifying for Tier 1 (See also: Exhibit 5) NYSE Arca: Effective Immediately -

FINRA announced that, effective October 15, 2012, Greg Ahern will join FINRA as Executive Vice President for Corporate Communications and Government Relations. Mr. Ahern previously served in a similar role at the Investment Company Institute. View news release here(links externally to FINRA website).

SIFMA has released a comment letter addressed to Spencer Bachus, Chairman of the House Financial Services Committee, expressing support for the Chairman's initiative to explore a "less burdensome legislative alternative" to the Volcker Rule. SIFMA cautions that the Volcker Rule could have substantial adverse effects on the U.S. and global economies, and that it targets activities which did not contribute meaningfully to the 2008 financial crisis. The letter makes three main arguments: (i) Congress should reevaluate the statutory text of Volcker, as the legislative process surrounding it was

SIFMA, along with 25 other trade associations, issued this joint letter opposing current proposals to use eminent domain to take mortgages from residential mortgage-backed securities. SIFMA and the coalition of trade groups are actively working together to advocate against what they believe to be an abuse of the sovereign power of eminent domain, and assert that such actions will cause irreparable damage to the housing market. Lofchie Comment : Leaving aside the substance of the letter and the very serious issues at stake for the economy, I note that the first page of the letter features a