U.S. Congress April 6, 2011 Senators Tim Johnson (D-SD) and Debbie Stabenow (D-MI) and Representatives Frank Lucas (R-OK) and Spencer Bachus (R-AL) sent a letter to Treasury Secretary Timothy Geithner, Board of Governors of the Federal Reserve System Chairman Ben Bernanke, SEC Chairman Mary Schapiro, and CFTC Chairman Gary Gensler advising regulators to provide an exemption from margin requirements for end-user derivatives transactions. The letter states: "Regulators should exempt end-users from margin requirements and seek to limit other regulatory burdens that could have the unintended

FINRA RN 11-16 April 7, 2011 FINRA published a regulatory notice to clarify the margin treatment for non-margin eligible equities under Regulation T. Pursuant to authority under FINRA Rule 4210(f)(8)(A)(ii), FINRA stated that maintenance margin for such securities held long in a Reg. T margin account shall be 100% of current market value. For short positions the requirements of RN 09-53 continue to apply for Reg. T accounts, but portfolio margin accounts will be subject to new specified requirements. In addition, the notice clarifies the treatment of non-margin eligible equities with respect

SEC Release No. 34-64251 April 7, 2011 The SEC amended Exchange Act Rule 19b-4(a) to clarify that the term "business day," as used thereunder, refers to days on which the SEC is open for regular business. Cross References Exchange Act Rule 19b-4 Exchange Act § 19(b)

FINRA News Release April 7, 2011 FINRA announced that it sanctioned two firms and seven individuals for selling interests in private placements without conducting a reasonable investigation. The FINRA actions allege that the firms failed to conduct proper due diligence on the offerings to ensure that they were suitable for their customers, and that they failed to enforce a supervisory system reasonably designed to achieve compliance with securities laws and regulations. Cross References NASD Rule 2110 (n/k/a FINRA Rule 2010) NASD Rule 3010

SEC Press Release 2011-86 April 7, 2011 The SEC announced settled administrative proceedings against three executives of a Florida-based broker-dealer alleging violations of customer privacy rules by improperly transferring customer records to another firm. The SEC also alleged that the firm failed to ensure that its policies and procedures were reasonably designed to safeguard confidential customer information. Cross References Regulation S-P, Rules 7(a), 10(a), 30(a) SEC Release No. 34-64222 (action against firm's CCO) SEC Release No. 34-64221 (action against firm's president) SEC Release No