Today RULE Briefs cover these topics:

1. FINRA Looks to Revise TRACE Reporting Fees for ABS Sales.
   
2. SEC Revises IA Registration Depository Fees.
3. NYSE Rule Change re: MOC, LOC Orders.
4. CBOE Rule Change re: MOC, LOC Orders.

    1.  FINRA Looks to Revise TRACE Reporting Fees for ABS Sales.   FINRA uses Trading Activity Fees to fund its member regulation activities.  Earlier this year, the SEC approved Asset-Backed Securities for TRACE reporting, scheduled to begin 5/16/11.  The current rate is $0.00075 per bond for each sale of a covered TRACE-Eligible Security, with a max charge of $0.75 per trade, which is based on the reporting of bond sales in $1000 bond units - e.g., so that 10 bonds equals a $10,000 bond position.  Such a fee structure would not work for many asset-backed securities, which will be reported to TRACE using original face value.  Accordingly, FINRA proposes tp accommodate that will a revised rate fee formula.  For further details, click onto:   [FINRA Rule Filing 10-67, 12/21]

     2.  SEC Revises IARD Fees.   The SEC issued a Notice of intent to charge revised IARD (Investment Adviser Registration Depository) filing fees, beginning on 1/1/11.  The new recommended fee levels would increase the fee for advisers with assets under management ("AUM") of $100 million or higher, but would not change the fee levels for advisers with AUM below $100 million.  The recommended annual filing fees due beginning 1/1 are:  (i) $40 for advisers with AUM under $25mn;  (ii) $150 for advisers with AUM from $25mn to $100mn;  and, $225 for advisers with AUM of $100mn or higher.  [SEC Release IA-3119,12/2]

     3.  NYSE Rule Change re: MOC, LOC Orders.   The NYSE filed for immediate effectiveness to amend Rule 123C to clarify that Exchange systems enforce the rule with respect to MOC and LOC order entry after 3:45 p.m. ET.  Members are not responsible for ensuring compliacne with this aspect of the rule.  [NYSE Rule Filing 10-75, 12/8]

     4.   CBOE Rule Change re: MOC, LOC Orders.  The SEC approved CBOE's proposal to amend its rules and the rules of the CBSX regarding registration, qualification, and CE requirements for individual trading permit holders ("TPHs") and their associated persons.  The amendments make them substantially similar to the registration, examination and CE requirements of FINRA.  And, specifically, CBOE would require all individual TPHs and TPH associated persons, regardless of whether they conduct a public customer or proprietary securities business, to register, qualify and comply with continuing education requirements.    [CBOE Rule Filing 10-84, 11/12]