The FSA issued a consultation paper/discussion paper that proposes a number of changes to the client assets regime for firms that undertake investment business. The paper proposed changes required by the European Markets Infrastructure Regulation ("EMIR"), and recommends changes that could lead to a radical shift in how firms are required to protect client assets. The changes could also have significant implications in connection with the bankruptcy of a clearing firm, both in terms of facilitating the reporting of client positions and improving the standing of clients in reclaiming their

To assist persons currently operating a pool pursuant to an exemption to CFTC Rule 4.13(a)(4) (Exemption From Registration as a Commodity Pool Operator) (which exemption is disappearing at the end of this year) that will be able to qualify for an exemption under CFTC Regulations 4.7, 4.12 or CFTC Advisory 18-96, NFA is modifying its Electronic Exemption System to permit these persons to pre-file for the applicable exemption. Lofchie Comment: Numerous funds are going to lose their Rule 4.13 exemption and it is to be expected that the NFA will be flooded both with new registrants and persons

The MFA submitted this comment letter in response to the CFTC's proposed clearing requirement determination rulemaking, expressing its strong support for the CFTC's decision to focus on certain classes of credit default swaps (CDS) and interest rate swaps in its initial clearing requirement determination. The MFA went on to express concerns specific to the iTraxx Europe CDS indices. Essentially, the MFA says that (as to any product that is required to be cleared) there must be a period of time in which clearing is voluntarily available to all customers, so that customers can test the operation

New rules, rule proposals and a withdrawal from FINRA, NYSE Arca, OCC and Phlx: FINRA: Proposed Rule - Amend the By-Laws of FINRA Dispute Resolution, Inc. to Clarify That Services Provided by Mediators Should Not Cause Them to Be Classified as Industry Members under the By-Laws NYSE Arca: Final Rule - Amend NYSE Arca Equities Rule 7.31(h) to Add a PL Select Order OCC: Final Rule - Amend OCC's By-Laws to Allow the Corporation to Approve OCC's Form of Clearing Member Application and Form of Clearing Agreement Phlx: Proposed Rule Withdrawal - Change to Modify Exchange Rule 3307 to Institute a

The table below indicates the dates, participants and subjects of the meetings. DATE MEETING WITH RULEMAKING ABOUT 09/06/2012 More Info ICAP General Participants to discuss Post-Trade and CFTC regulations. 09/06/2012 More Info CitigroupCleary Gottlieb Steen Hamilton General Topic of discussion: cross-border issues. 09/06/2012 More Info Bank of America General Participants discussed guidance on ET applications. 09/06/2012 More Info ICAP, TriOptima SEF Registration Participants discussed portfolio compression and bulk risk mitigation services. 09/05/2012 More Info BP Attendees discussed BP swap