[ by Howard Haykin ]

Michael Macchiaroli, Associate Director of the SEC's Division of Trading and Markets, issued a Staff "No-Action Letter" to FINRA EVP Grace Vogel in late November regarding the "Definition of 'Ready Market' with regard to Foreign Securities pursuant to Rule l5c3-1(c)(11)(i)."

Ms. Vogel's opening paragraph summarized the relevant issue, as follows:

The Financial Industry Regulatory Authority, Inc. ("FINRA") is hereby requesting assurance that the staff of the Division of Trading and Markets ("Division") of the Securities and Exchange Commission ("SEC" or "Commission") would not recommend enforcement action under Rule15c3-1 of the Securities Exchange Act of 1934 ("Exchange Acr'), if broker-dealers, under the conditions described [within the letter of request], treat certain foreign equity securities as having a "ready market" under Exchange Act Rule 15c3-1 (c )(11) and subject to the haircuts under paragraph (c)(2)(vi)(J).  FINRA notes this would expand the number of foreign securities eligible as foreign margin stock under the Board of Governors of the Federal Reserve System's ("Federal Reserve") Regulation T.

To access the complete request and "No Action" response, go to:   [SEC No Action Letter, 11/28/12].