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Comment Letter (SIFMA) SIFMA submitted comments to the SEC on a proposed rule that would extend temporary Rule 206(3)-3T under the Investment Advisers Act (IAA), for an additional two years beyond its scheduled expiration on Dec. 31, 2010. The rule establishes a means for broker-dealers to comply with § 206(3) of the IAA. SIFMA strongly favors an extension of Rule 206(3)-3T, arguing that the principal trading relief in the rule is more favorable to investors than dealings solely on an agency basis. SIFMA further suggests the rule should be made permanent and expanded, and reiterates its

SEC Release (Rulemaking) The SEC is requesting public comment on a study it is conducting, pursuant to § 939(h) of the Dodd-Frank Act, on the feasibility and desirability of standardizing credit ratings terminology. Document Number SEC Release 34-63573 Date December 17, 2010 Cross Reference (links require a Cabinet subscription) Dodd-Frank § 939(h)

News Article Intercontinentalexchange Inc said on Thursday it withdrew an application to register its credit default swaps trading as a derivatives clearinghouse with the CFTC because of "the significant changes proposed to the commission regulations," a company spokesman said. The withdrawal comes a week after the CFTC proposed a rule that addresses part of the law requiring clearinghouses to have strong risk management standards and provide "fair and open access" to potential members. Gary Gensler, chairman of the agency, has in the past complained that swaps clearinghouses acted like

Commentary Arguing that the American public is "furious at the banks, whose recklessness has led to crisis and recession - and high unemployment," the NY Times editorializes against the new Republican House's efforts to derail the SEC and CFTC's implementation of Dodd-Frank. The NY Times opines: "To their credit, regulatory agencies have begun that process with a sense of mission and depth of expertise that was missing in the years before the financial crisis. In particular, the Securities and Exchange Commission and the Commodity Futures Trading Commission - which share the all-important

News Article As the GOP prepares to seize control of the House in January, its members on the Financial Services Committee are vowing to reexamine the wide-ranging financial regulatory legislation passed earlier this year. Rep. Spencer Bachus (R-Ala.), the incoming committee chairman, said in an interview that Republicans want to revisit provisions that would require companies that use derivatives merely to hedge risks - such as an airline guarding against swings in fuel prices - to set aside more capital for those deals. Bachus said such "end users" did not contribute to the financial crisis