Commentary February 8, 2011 Page 6 CFTC and Dodd-Frank items on pp. 4-5 Interview with CFTC Commissioner Bart Chilton, excerpts: Regarding DF deadlines: "The law is the law," Chilton chimes in. "We have deadlines. If lawmakers want to change the law, fine. I don't think they will. Until then, we move forward." Regarding cuts in CFTC funding: "I don't think the cut in funding will stop us from writing the regs. The lack of funding will only hurt surveillance and enforcement of the new rules. So, in a year's time, it may be against the law to do something, we just may not be able to enforce it

News Article Financial Times February 8, 2011 Regulators' plans to require the public reporting of large swap transactions 15 minutes after they are traded have been criticised by big derivatives markets participants including Pimco, Blackrock and Freddie Mac. The CFTC proposed last year that large swap trades and so-called 'block trades' be reported within 15 minutes, a dramatic departure from the current market practice, where trading is done privately and details are not made public. Many in the derivatives industry are unhappy with the short reporting period, and such concerns dominated

File No. S7-18-08 February 9, 2011 SEC Proposes the first in series of amendments to Rules and forms to remove references to credit ratings. Cross References Rules 134, 138, 139, and 168, under the Securities Act; Forms S-3, S-4, F-3, F-4, and F-9. Schedule 14A under the Securities Exchange Act.

SEC Release 33-9186 / 34-63874 February 9, 2011 The SEC proposed rule amendments that, in accordance with § 939A of Dodd-Frank, would remove credit ratings as one of the conditions for companies seeking to use short-form registration when registering securities for public sale. Instead of ratings, the new short-form test for shelf-offering eligibility of companies would be tied to the amount of debt and non-convertible securities they have sold in the past three years. Cross References SEC Press Release 2011-41 Dodd-Frank § 939A Securities Act Rule 134 SEC Forms S-3, F-3, F-9

February 1, 2011 OFAC Released new Civil Penalties Information on Feb. 2, 2011.