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What's New: SEC clarifies conformance periods for the Volcker Rule. April 19, 2012 Policy Statement NASDAQ Files a Proposal to Establish the Market Quality Program for ETFs. Comments due by May 3rd. For the rule filing dated April 6, 2012 click here. STANY comments on the Volcker Rule STANY's Comment Letter on the Volcker Rule - February 2012 STANY comments on FINRA Regulatory Notice 11-43 IOI proposal STANY_Comment_FINRA_Rule5210_IOIS STANY files comment letter with SEC on Short Sale Reporting Study required by the Dodd-Frank Act STANY_Comment_Short_Sale_Reporting STANY files comment letter with SEC on Limit Up-Limit Down The deadline for firm's CEO's to sign off on Market Access Rule complicance of July 14th is looming. Critical elements of a reasonably designed system include: -
Risk management in real-time (not end-of-day.) -
Following the MPID to determine responsibility for compliance -
Cross-asset class and cross-market obligations -
Consideration of requirements by individual order and by aggregate order. For the SEC's Final Rule click here. SEC Seeking Comment on Short Sale Reporting Study The SEC is seeking comment on the feasibility, benefits, and costs of -
requiring reporting in real-time, either publicly or to the Commission and FINRA of short positions of publicly listed securities, and -
of conducting a voluntary pilot program in which public companies would agree to have all trades of their shares marked "long," "short," Market market short," "buy," or "buy-to-cover," and reported as such in real time through the Consolidated Tape. For the SEC Release and to submit comments to the Commission click here.
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