FINRA RN 11-12 March 18, 2011 FINRA published a regulatory notice to remind firms of their obligations under the Foreign Corrupt Practices Act (FCPA). The notice advises firms to review their business practices to ensure compliance with the FCPA, and notes that a failure to comply with the FCPA would be deemed a violation of FINRA Rule 2010 (standards of commercial honor and principles of trade). The notice provides a general overview of FCPA requirements and to what extent they apply to different types of broker-dealers. Cross References Exchange Act § 13(b) FINRA Rule 2010 CWT CF Memo, SEC

SEC Release No. 34-64084 (SR-FINRA-2011-012) March 16, 2011 The SEC published a FINRA proposal to amend the FINRA Rule 6700 and 7730 series to make a series of technical and conforming changes relating to the reporting of asset-backed securities. Among other things, the rule change would (i) consolidate reporting requirements for ABS transactions executed off-hours; (ii) simplify settlement reporting for ABS transactions; (iii) add alternative reporting rules for ABS transactions that are pre-issuance SMO/REMIC transactions; and (iv) clarify firms' obligations to report information to FINRA

March 22, 2011 ISDA has published a revised draft of the Credit Derivatives Determinations Committees Rules, which has been approved by each of the five Determinations Committees, for public comment. The amendments include the implementation of the June 11, 2010 Amendments and a number of clarificatory amendments. The final version of the DC Rules will be published on the ISDA website on Tuesday 29th March 2011.

CFTC PR 6009-11 March 23, 2011 The CFTC is requesting public comment on a petition submitted by the Options Clearing Corporation (OCC) to amend a November 5, 2004 Order issued by the Commission under Section 4d of the Commodity Exchange Act. The Order permits OCC to operate an internal non-proprietary cross-margining program for market professional customers who trade futures products and securities products that are cleared by OCC in its capacity as a derivatives clearing organization and a securities clearing agency, respectively. Cross References CEA Sec. 4d

CFTC Speeches March 22, 2011 Chairman Gary Gensler speaking in Brussels discusses Dodd-Frank and reiterates one of his favorite themes-the role that swaps allegedly playing in the financial meltdown of 2008. "Though there were many causes to the crisis in 2008, it is clear that swaps played a central role. They added leverage to the financial system with more risk being backed up by less capital. U.S. taxpayers bailed out AIG with $180 billion when that company's ineffectively regulated $2 trillion swaps portfolio, managed from London and cancerously interconnected to other financial