Financial Services Authority April 27, 2011 On 27 April 2011, the FSA published guidance on the Individual Liquidity Systems Assessment (“ILSA”) submission information document. The ILSA submission information document is intended to give Individual Liquidity Adequacy Standards firms, pursuant to the Prudential sourcebook for Banks, Building Societies and Investment Firms, information on what the FSA requires them to include in an ILSA. The core of the submitted information will comprise an evaluation of compliance levels and sources of liquidity.

SEC Release No. 34-64383 May 3, 2011 The SEC published a notice, as required by Dodd-Frank, to solicit public comment on certain studies regarding short sales. In particular, the notice solicits comment on (1) the feasibility of requiring real-time reporting of short sale positions in publicly listed securities; and (2) conducting a pilot program in which all trades in public equities would be marked "long," "short," "market maker short," "buy," or "buy-to-cover," and reported in real-time over the CTA. The notice also solicits public comment on Dodd-Frank's requirement that the SEC adopt

CFTC Speeches "Avoidable" May 4, 2011 CFTC Commissioner Bart Chilton talks about the need for the CFTC to be more "pro-active" and repeats his critique of high-frequency trading and the role of "massive passives," i.e., index funds in the financial markets. Cross References Dodd-Frank Act, Title VII

Financial Services Authority May 3, 2011 The FSA has published a Policy Development Update. The update includes publications issued since the last edition: Quarterly consultation paper No.28; and Use of non-EEA rules in calculating group capital requirements. The update also includes information about recent Handbook-related and other developments, other publications - consumer publications, guidance consultations and finalised guidance and an updated timetable for forthcoming publications.

SEC Litigation Release No. 21956 May 4, 2011 The SEC announced the filing a settled civil action against a broker-dealer for its alleged rigging of municipal bond reinvestment transactions. The SEC action alleged that the broker-dealer, among other things, facilitated improper payments to other bidding agents in connection with the competitive bidding process for the temporary investment of municipal bond offering proceeds. The settlement was entered into in concert with the Department of Justice, the IRS, and a number of state attorneys general. Cross References Exchange Act § 15(c) SEC Press