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CFTC Press Release 6144-11 CFTC Staff Letter The CFTC's Division of Market Oversight issued a letter to market participants requiring compliance with the new large trader reporting system for physical commodity swaps and swaptions. Clearing organizations and clearing members must begin reporting under the new system on November 21, 2011, and the Division requires fully compliant month-end open interest reports to be collected beginning September 2011 through February 2012 and submitted to the Commission by March 20, 2012. The Division is providing a temporary and conditional safe harbor for

SEC Release No. 34-64976 July 27, 2011 The SEC adopted new Exchange Act Rule 13h-1 and Form 13H under the Exchange Act to require “large traders” (defined as those whose transactions in NMS securities is (i) equal to or greater than 2 million shares or $20 million on any day or (ii) 20 million shares or $200 million dollars during any calendar month) to identify itself to the SEC and make certain disclosures. Such large traders must provide an identification number to the broker-dealers through whom they trade, who must then maintain particular records of any transactions effected for the

76 FR 43851 The CFTC is adopting reporting regulations that require physical commodity swap and swaption reports. The new regulations require routine position reports from clearing organizations, clearing members and swap dealers and also apply to reportable swap trader positions. Effective Date: September 20, 2011 Cross References Dodd-Frank Act, Title VII; CEA Secs. 4a, 4t and 8a(5); 17 CFR Parts 15 and 20

U.S. Congress April 6, 2011 Senators Tim Johnson (D-SD) and Debbie Stabenow (D-MI) and Representatives Frank Lucas (R-OK) and Spencer Bachus (R-AL) sent a letter to Treasury Secretary Timothy Geithner, Board of Governors of the Federal Reserve System Chairman Ben Bernanke, SEC Chairman Mary Schapiro, and CFTC Chairman Gary Gensler advising regulators to provide an exemption from margin requirements for end-user derivatives transactions. The letter states: "Regulators should exempt end-users from margin requirements and seek to limit other regulatory burdens that could have the unintended

SEC Release No. 34-64087 March 17, 2011 The SEC published a proposal to "readopt" certain provisions of Exchange Act Rules 13d-3 and 16a-1 in order to clarify that persons who purchase or sell security-based swaps will be within the scope of those rules after the effective date of new Exchange Act § 13(o) (July 16, 2011). The SEC notes that this proposal is only intended to "preserve the existing application of the beneficial ownership rules as they relate to security-based swaps." However, the SEC adds that the staff is also engaged in a project to "modernize" the reporting rules under