The attached guidance document has been prepared by the staff of the SEC Division of Investment Management, and includes a list of no-action letters which funds engaging in securities lending can rely upon. The following areas are addressed: Approval of fees paid; Benefits must be commensurate with the risks; Board's fiduciary duty to invest the fund's assets in accordance with fund's investment goals; Compensation to the lending fund; Delegation of authority to negotiate loans; Directors' fiduciary duty to act in the best interests of fund shareholders; Investment segregation; Loan

SIFMA and 17 other associations submitted the attached comments to the Office of Management and Budget ("OMB") and the National Economic Council ("NEC") urging the OMB to affirm an exemption from sequestration for payments to issuers of direct payment bonds. The groups further urged an exception for direct subsidy bonds from sequestration similar to what is currently provided for individual refundable tax credits or other permanent appropriations. Lofchie Comment: I confess that I have no idea what this letter is even about. What I found interesting was its spare look and the absence of trade

The CFTC announced an opportunity for public comment on the proposed extension of its current approval from the Office of Management and Budget ("OMB") of an information collection request ("ICR") titled "Exemptive Order Regarding Compliance with Certain Swap Regulations." Click here to view notice in full (links externally to Federal Register website).

In a speech before the Global Markets Advisory Committee ("GMAC"), CFTC Commissioner Jill Sommers stated that the CFTC was seeking comments to apply a "sensible approach to . . . cross-border matters," and announced that Ron Filler (current Director of the Center for Financial Services Law at New York Law School) would be serving in a newly created role as an outside GMAC Chairman. Lofchie Comment: Mr. Filler is a well-known and respected figure within the derivatives industry. Given the very significant criticism that the CFTC has absorbed as to its existing assertions of extra-territorial

New rules and rule proposals from BOX, EDGA, and EDGX. Click on the links to view the SEC's notices of each rule change and proposal. BOX: Effective Immediately - Rule Change to Amend the Fee Schedule for Trading on BOX (See also: Exhibit 5) EDGA: Effective Immediately - Rule Change Relating to Amendments to the EDGA Exchange, Inc. Fee Schedule (See also: Exhibit 5) EDGX: Effective Immediately - Rule Change Relating to Amendments to the EDGX Exchange, Inc. Fee Schedule (See also: Exhibit 5)