Request for Comment

MSRB Request for Comment on Trade Size Information

On June 1, 2012, the MSRB published a request for comment on a proposal to provide for more rapid public dissemination of trade size information for large municipal securities transactions through the MSRB Real-Time Transaction Reporting System. Comments must be submitted no later than July 2, 2012. MSRB Request for Comment.

Agencies Request for Comment on Market Risk Capital Rules

On December 7, the OCC, Fed, and FDIC released a notice of proposed rulemaking to seek comment on an amendment to a December 2010 notice of proposed rulemaking to modify the agencies’ market risk capital rules for banks with significant trading activities. The new notice of proposed rulemaking proposes to replace the use of credit ratings with new methodologies to determine risk-specific capital requirements for debt and securitization positions. Comments must be submitted by February 3, 2012. Joint Release. Proposed Rule.

MSRB Request for Comment on Definition of Sophisticated Municipal Market Professional

On November 8, the MSRB requested comment on updating its definition of sophisticated municipal market professional to reflect recent changes to both the availability of municipal market information and to FINRA’s rules on suitability for institutional accounts. Comments to the proposed definition must be submitted by December 13. MSRB Release.

Discussion Paper and Request for Comment on Alternative Mortgage Servicing Compensation

On September 27, the FHFA announced that the Joint Initiative on Mortgage Servicing Compensation is seeking comment on two alternative mortgage servicing compensation structures. One proposal would establish a reserve account within the current servicing compensation structure and the other would create a new “fee for service” compensation structure. Comments must be submitted within 90 days of the proposal. FHFA Release. Discussion Paper.

SEC Request for Comment on Short Sale Disclosure

On May 4, the SEC issued a request for comment on short selling disclosure regimes relating to transaction reporting and position reporting. Pursuant to Section 417 of the Dodd-Frank Act, the SEC is required to study both regimes and submit a report to Congress by July 21. Comments must be submitted within 45 days after publication in the Federal Register. SEC Release.