SEC Release No. 34-64148 March 30, 2011 Federal financial regulatory agencies published a proposal to implement the risk retention requirements of Exchange Act Section 15G (as added by Section 941 of Dodd-Frank) to require asset-backed securitizers to retain at least 5% of the credit risk of the assets collateralizing asset-backed securities. The statute contains a number of exemptions from this requirement, in particular for securities collateralized entirely by certain "qualified residential mortgages" (defined in the proposal). Comments on the proposal (which is nearly 400 pages) are due by

European Parliament March 30, 2011 The European Parliament's Committee on Economic and Monetary Affairs has published Amendments 697 to 975 in relation to the Draft Report on the proposal for a regulation on OTC derivatives, central counterparties and trade repositories.

SEC Release 34-64166; SR-FINRA-2010-035 April 1, 2011 The SEC published for comment a FINRA proposal to amend FINRA's Discovery Guide (including Document Production Lists) and to make conforming changes to Rules 12506 and 12508 of the Code of Arbitration Procedure for Customer Disputes. Cross References SEC Release 34-62584 (Proposal) FINRA Rules 12506, 12508

SEC Release 33-9200 / 34-64182 April 5, 2011 The SEC announced a settled civil fraud action against a broker-dealer allegedly engaged in misconduct in the sales of two CDOs tied to the performance of residential mortgages. The release alleges that the firm charged "undisclosed excessive markups" in the sale of certain CDO shares. In addition, the release alleges that the firm misrepresented to investors the price it paid for certain mortgages obtained from an affiliate to form a CDO. The firm settled the charges, which include violations of Securities Act Section 17(a)(2)-(3) (but, notably

SEC Release 34-64167; SR-OCC-2011-03 April 1, 2011 The SEC published for comment a proposal of the Options Clearing Corporation to expand its internal cross-margining platform to permit affiliated clearing members to establish a cross-margining account in which securities and security futures cleared by OCC can be cross-margined with commodity futures and options on such futures cleared by OCC. Cross References Commodity Exchange Act Section 4d Exchange Act Section 17A