August 4, 2011 The recent defeat of the SEC's proxy access rule in a federal appeals court could embolden industry groups to mount similar legal challenges to other rules required by the Dodd-Frank financial oversight law. Many of the comment letters to federal regulators, as well as congressional testimony, appear to be laying the groundwork for possible lawsuits. Much of the language used hints at challenges to federal rulemaking procedures, particularly flaws in economic analysis or a failure to properly review all of the public comments. Of the five rules that the article mentions may be

London-based Forex Capital Markets Ltd. Ordered to Pay $140,000 Penalty to Settle CFTC Charges of Acting as an Unregistered Retail Forex Exchange Dealer Order: Forex Capital Markets Ltd. August 3, 2011 CFTC Press Release 6087-11 The CFTC settled charges that Forex Capital Markets Ltd. of London, U.K. acted as a retail foreign exchange dealer (RFED) by conducting retail leveraged forex transactions with U.S. customers without registering with the CFTC under the agency's regulation 5.3(a)(6)(i). The CFTC order finds that, from October 18, 2010 through October 29, a period of 11 days immediately

Financial Services Authority July 29, 2011 The purpose of the Consultation Paper (CP) is to seek views on the FSA's proposals to amend the Client Assets Sourcebook (CASS). Following the financial crisis and, in particular, the collapse of Lehman Brothers International (Europe) (LBIE), the FSA have enhanced the client assets regime through previous proposals. There are a number of proposals in the paper which to which the FSA seek a response. There are proposals on three different matters relating to the lien rules in CASS. These are: interim relief from the effect of the existing rules from

Technology Advisory Subcommittee Meeting on Data Standardization CFTC Press Release 6080-11 Agenda July 26, 2011 The CFTC announced that Subcommittee on Data Standardization, a new Subcommittee of the CFTC's Technology Advisory Committee will hold a public meeting on August 5, 2011 to look into public/private solutions for creating well-accepted standards for describing, communicating, and storing data on complex financial product.

CFTC Commissioner Scott D. O'Malia Seeks Public Comment on the Review of Swaps for Mandatory Clearing Re: Review of Swaps for Mandatory Clearing under Section 723 of the Dodd-Frank Act (the "Act") July 28, 2011 CFTC Commissioner Scott D. O'Malia issued a letter to the public seeking comment on the manner in which the Commission should determine (i) which swaps would be subject to the clearing requirement and (ii) whether to grant a stay of a clearing requirement. His letter is issued independent of that of the Commission. Cross References Dodd-Frank Act, Title VII, Sec. 723