SIFMA submitted a letter to the CFTC requesting the Commission to provide interpretive guidance and other appropriate relief with the result that insurance-linked securities (ILS) transactions will not be regulated as commodity pools under the Commodity Exchange Act by Title VII of the Dodd-Frank Act. The request for relief extends to those ILS transactions that do not satisfy the non-exclusive safe harbor for certain insurance transactions not being a swap as a result of (i) the cedant's primary regulator being outside the U.S. and consequently failing to meet the "Provider" test and/or (ii)

FINRA filed with the SEC the attached proposed rule change to extend the expiration date of FINRA Rule 0180 (Application of Rules to Security-Based Swaps) to July 17, 2013. FINRA Rule 0180 temporarily limits, with certain exceptions, the application of FINRA rules with respect to security-based swaps. Click hereto view the text of the proposed rule change (links externally to FINRA website).

A federal district court in Washington rejected arguments by the U.S. Chamber of Commerce and the Investment Company Institute that a CFTC rule requiring mutual funds with commodity investments to register with the agency is unnecessary, and that the CFTC didn't properly assess the costs and benefits when it approved the regulation in February. "The court is satisfied that the CFTC considered the relevant factors, acted well within its discretion, and that there was nothing arbitrary or capricious about the CFTC's actions in promulgating the final rule," Judge Beryl Howell wrote in the

FINRA is filing with the SEC a proposed rule change to amend NASD Rule 1022 (Categories of Principal Registration) and NASD Rule 1032 (Categories of Representative Registration) to extend the deadline by which eligible registrants must complete a firm-element continuing education requirement to engage in a security futures business. The extension is to December 31, 2015, or one business day prior to the date a revised examination that includes security futures products is offered. The filing suggests that there may not be enough security futures business to justify FINRA revising its exams to

CFTC Commissioners Bart Chilton and Jill E. Sommers (Chair of the Global Markets Advisory Committee) delivered testimony on the status of Dodd-Frank before the U.S. House of Representatives Committee on Agriculture Subcommittee. Commissioner Sommers shared her view on the challenges facing regulators across the globe in trying to meet the commitments on over-the-counter (OTC) derivatives reform made by G20 Leaders in 2009 as well as the challenges presented in interpreting the cross-border scope of Dodd-Frank. In particular, Sommers highlighted five areas which need further exploration