The U.S. Department of Treasury removed all references to, or requirement reliance on, "credit ratings" in the IRS Code pursuant to Section 939A ("Removal of Statutory Reference to Credit Ratings") of Dodd-Frank. Additionally, the Treasury Department added substitute standards of credit-worthiness where appropriate. See: 78 FR 54758.

The SEC charged Lawrence Polizzotto, former head of investor relations at Arizona-based solar energy company First Solar Inc., with violating Regulation FD ("Fair Disclosure"). The SEC alleges that Polizzotto violated Reg. FD when he indicated in phone conversations with analysts and investors that the company was less likely than the company's management had previously indicated to receive an anticipated loan guarantee from the U.S. Department of Energy. Bondi Comment: The case illustrates the difficulty of managing a situation where an individual speaking with investors is aware of negative

The Futures Industry Association ("FIA") released a set of recommendations for increasing the usefulness of Drop Copy systems in exchange-traded markets. Drop Copy systems provide a way to monitor trading activity in real-time, and help maintain the risk management processes of brokers, trading firms, and end-users. The systems produce reports generated at the point of execution that summarize a participant's activity in a trading venue, including order state changes, modifications, rejections, and cancellations. FIA offered the recommendations in order to help promote the wider adoption and

The Delta Strategy Group released an update regarding the Basel Committee on Banking Supervision's and the International Organization of Securities Commissions' (" IOSCO") final framework for margin requirements for non-centrally cleared derivatives released on September 2. Under these global standards, all financial firms and systemically important non-financial entities that engage in non-centrally cleared derivatives will have to exchange initial and variation margins commensurate with the counterparty risks arising from such transactions. See: Click here to see the Basel Committee and

The Alternative Investment Management Association ("AIMA") published an enhanced statement of AIMA policy principles. The paper establishes the AIMA's core set of beliefs in investor protection, regulatory consistency, systemic risk and market integrity. See: AIMA Enhanced Statement of Policy Principles.