FIA ISDA RIN 3038-AD21 April 1, 2011 FIA and ISDA File Comment Letter on Commodity Options and Agricultural Swaps (April 1, 2011) FIA and ISDA filed a joint letter on April 1 commenting on the CFTC's proposed rule on the regulation of commodity options and agricultural swaps that are traded over-the-counter. The two associations expressed support for the proposal to apply the same rules to agricultural swaps that apply to all other OTC commodity derivatives under the Dodd-Frank Act, rather than applying separate or more restrictive rules to these products, and to treat agricultural trade

SEC Release No. 34-64191; SR-DTC-2010-15 April 5, 2011 The SEC approved a DTC proposal to remove a requirement that transfer agents that use its Fast Automated Securities Transfer ("FAST") program must maintain a balance certificate for exchange-listed issues that participate in the direct registration system. Cross References SEC Release No. 34-63320 (proposal)

SEC Release No. 34-64196 April 6, 2011 The SEC approved a rule proposal by the Options Clearing Corporation that seeks to provide clarification regarding the regulatory capital treatment under Exchange Act Rule 15c3-1 of collateral and margin posted by clearing members participating in stock loan transactions through OCC's Stock Loan/Hedge Program or Market Loan Program. The OCC program allows firms to submit broker-to-broker stock loan transactions to OCC for clearance. Cross References SEC Release No. 34-63623 (proposal) Exchange Act Rule 15c3-1

HM Treasury April 6, 2011 On 6 April 2011, the UK government and the FSA published a review of the UK's covered bond regulation. The review proposes measures relating to transparency and standardised investor reporting which will better align the UK's covered bond market with its continental competitors. The review also suggests that secured creditors' rights to collateral should not be usurped in the event of any exercise of any future 'bail-in' powers. Responses to the review are solicited by 1 July 2011.

CFTC No-Action Letter 11-01 March 22, 2011 The Division of Clearing and Intermediary Oversight provided no-action relief to the general partners of two commodity pools from registering as CPOs under Section 4m(1) of the Commodity Exchange Act, and allowed an affiliated, registered CPO ("designee") to serve as the CPO of the pools instead, where, among other things: (1) the general partners and the designee are under common ownership and control; (2) the general partners have delegated all of their management authority to the designee; (3) the general partners do not engage in the solicitation