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The SEC granted a request for relief from Section 11(d)(1) of the Securities Exchange Act of 1934 with respect to extensions of credit on ETF shares by Charles Schwab & Co., Inc. The SEC confirmed that Schwab could extend margin credit on the ETF shares in spite of the fact it had certain (very limited) business relationships with persons involved in the distribution of the shares. The relationship between Schwab and the ETF providers existed essentially to allow Schwab to hold conferences with respect to ETFs and would not have resulted in any direct cash compensation to Schwab. In effect

ABA, et al.: ABA, The Clearing House, FSF, FSR, FIA, IIB, ISDA, ICI/ICI Global, MFA and SIFMA submitted a joint comment letter requesting that the CFTC extend the comment deadline on the cross-border proposed interpretive guidance and proposed exemptive order. Association for Financial Markets in Europe (AFME): AFME addressed whether the substituted compliance process is the most effective way to achieve the goals as set forth in Title VII of the Dodd-Frank Act. Association of German Banks: The Association stated its concerns that such regulatory efforts by the CFTC may lead to unnecessary

Lofchie Comment on Responses to the CFTC's ET Guidance: I had recently published a memo pointing out a variety of ways in which I believed the reach of Dodd-Frank (Title VII in particular) was either overbroad in its application to non-U.S. entities or discriminatory as to the treatment of non-U.S. entities in ways that I thought were not likely to be acceptable. Today, we publish in the news a summary of various comments as to the CFTC's proposed guidance on the reach of Dodd-Frank outside the United States. The comments from foreign governments are uniformly critical.When other responsible

The CFTC is adopting certain conforming amendments to the CFTC's regulations regarding the registration of intermediaries consistent with other CFTC rulemakings issued pursuant to the Dodd-Frank Act and other non-substantive, technical amendments to its regulations. The conforming amendments consist largely of added references, where appropriate, to rules relating to SDs, MSPs and swap execution facilities (SEFs). Effective Date: October 29, 2012 Cross Reference(s): Dodd Frank Title VII. The following CFTC rules are to be amended by this release: 3.1 (Definitions) 3.2 (Registration processing