Gregory A. Uffner

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On January 8, the Commodity Futures Trading Commission Division of Market Oversight issued a no-action letter (the Letter) supplementing the relief provided in CFTC Letter 17-27. CFTC Letter 17-27 generally permitted swap execution facilities (SEFs) and designated contract markets (DCMs) to correct clerical or operational errors discovered after a swap has been cleared.
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On November 12, the Commodity Futures Trading Commission (CFTC) published a proposed rule that would amend CFTC Regulation 160.30 by establishing specific requirements for policies and procedures to protect customer records and information (Detailed Requirements). The Detailed Requirements were inadvertently deleted in a 2011 amendment to the regulation.
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On November 13, the National Futures Association (NFA) issued Notice to Members 1-19-25, announcing that amendments to NFA Compliance Rule 2-29 and NFA Compliance 2-36 will become effective on January 1, 2020.  Compliance Rules 2-29 and 2-36 and related Interpretive Notices establish requirements for an NFA Member’s communications with the public and use of promotional material.
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CBOE Exchange, Inc. (CBOE) recently filed a proposal to amend its Rule 6.49A to amend provisions related to permissible off-floor position transfers. Generally, CBOE Rule 6.49A(a) specifies limited circumstances in which CBOE Trading Permit Holders (TPHs) may transfer their positions off the floor. CBOE proposes to add four events where an off-floor transfer would be permitted to occur. …
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On May 8, the Division of Enforcement (the “Division”) of the Commodity Futures Trading Commission issued its first public enforcement manual (the “Enforcement Manual”). The Enforcement Manual explains the roles of the CFTC and Division generally, and outlines certain general policies and procedures that guide the Division in its investigation and prosecution of violations of the Commodity Exchange Act (CEA) and CFTC Regulations.…
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On April 12, the Financial Industry Regulatory Authority (FINRA) published a regulatory notice (the “Notice”) requesting comment on a proposed pilot program to study proposed changes regarding corporate bond block trade dissemination based upon recommendations by the Fixed Income Market Structure Advisory Committee (FIMSAC) of the Securities and Exchange Commission. The changes are aimed at improving corporate bond block trade dissemination—mainly, by increasing block liquidity without imposing significant costs on market participants. Currently, FINRA’s Trade Reporting and Compliance Engine (TRACE) provides information to the marketplace regarding corporate bonds and other debt securities. It is intended that the pilot program will study FIMSAC’s recommendations to determine whether such recommendations can enhance current TRACE protocols.…
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The Securities and Exchange Commission has approved a proposed rule change to amend Financial Industry Regulatory Authority (FINRA) Rule 4512 (Customer Account Information) (the “Amended Rule”). For discretionary accounts, member firms are currently required to maintain a record of the dated, manual signature of each named, natural person authorized to exercise discretion in such accounts. The Amended Rule will allow for the use of electronic signatures in connection with discretionary accounts. …
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The US Securities and Exchange Commission has begun looking into whether the current multi-tiered pricing system used by stock exchanges favors large brokers and traders at the expense of small ones. In an effort to increase the volume of trading on an exchange, certain exchange operators (including New York Stock Exchange-owner Intercontinental Exchange Inc., Nasdaq Inc. and CBOE Global Markets) provide large brokers, banks and traders with rebates based on the amount of business they bring to the stock exchanges. …
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