CFTC Meetings 76 Fed. Reg. 25309 May 4, 2011 The CFTC's Agricultural Advisory Committee will hold a public meeting on May 19, 2011 to discuss issues related to the Dodd-Frank Act. Cross References Dodd-Frank Act, Title VII

Bank of America Corp., SEC No-Action Letter April 29, 2011 The SEC staff granted relief to Bank of America Corp. (BAC) under Section 30(h) of the Investment Company Act in connection with the sale of certain variable rate demand preferred shares of closed-end investment companies which may cause BAC to have a greater than 10% equity stake in the investment companies. By its terms, Section 30(h) would subject such BAC to the reporting requirements of Section 16(a) of the Exchange Act. In granting relief, the SEC noted that the transactions in which BAC is entering would not provide the firm

European Union April 29, 2011 The Council of the EU have published a Presidency compromise proposal, in particular with a view to discussions at the meeting of the Working Party of Financial Services AttachÉs on 3 May. Additional detail is given regarding payment systems, and the calculating of dates for when clearing obligations take effect. Most other changes are clean-up in nature, and are not substantive.

SEC Release No. 34-64374 / IA-3191 May 2, 2011 The SEC published a settled administrative action against a New York-based hedge fund manager alleged to have violated Rule 105 of Regulation M. The release alleges that the firm, on four occasions, purchased shares from an underwriter or offering participant in a follow-on public offering after having sold the relevant security short during the restricted period. The action resulted in a $400,000 civil penalty and over $1 million in disgorgement. Cross References Reg. M, Rule 105

SEC Release No. 34-64369; SR-FINRA-2011-021 April 29, 2011 The SEC declared immediately effective a FINRA proposal to delay until October 3, 2011, the implementation date of amendments to FINRA Rules 7410 and 7470 that expand the recording and reporting requirements of OATS to all NMS stocks. The rules had previously been scheduled to become effective on July 11, 2011. Cross References FINRA Rules 7410, 7470 SEC Release No. 34-63311 (approving rule changes) FINRA RN 11-03 (announcing previous effective date)