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

CFTC Dodd‑Frank Rulemaking The CFTC is proposing new rules and amended guidance and acceptable practices to implement the new statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act that, among other things, amends Section 5 of the CEA concerning designation and operation of contract markets, and adds a new CEA Section 2(h)(8) to include the listing, trading and execution of swaps on designated contract markets. The proposed rule takes up 66 pages of the Federal Register. Document Number 75 Fed. Reg. 80572 Date December 22, 2010 Cross

NFA - Notices to Members I-11-01 NFA is providing the guidance based upon a letter from the CFTC's Division of Clearing and Intermediary Oversight to assist members in complying with the requirements as they relate to the disclosure of conflicts of interests arising from the collection of incentive fees by CPOs and CTAs Date January 5, 2011 Cross References (links require a Cabinet subscription) CFTC Rules 4.24(j) and 4.34(j)

News Article Bart Chilton, the outspoken CFTC commissioner, said Tuesday he is reluctant to support the CFTC's issuance of a proposal on position limits because what has been suggested so far has not met the congressionally mandated implementation schedule. Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the CFTC was supposed to have a final rule by mid-January on what kind of limits traders would have in the agricultural, energy and metals markets. Last month the CFTC said it would miss that target. On December 16, the CFTC introduced its plan to curb speculation in

SEC Press Release The SEC announced a settled enforcement action against two Charles Schwab entities and their employees for making material misstatements in marketing a "YieldPlus" fund as a "cash alternative" despite the presence of significant market risk in the securities the funds invested in. The SEC actions allege violations of a number of provisions of the securities laws, including anti-fraud charges under the Securities Act against the Schwab entities, and 10b-5 charges against the individuals. The Schwab entities paid over $110 million to settle the actions. Please contact any of