Comment letter MFA submitted a comment letter to the CFTC in response to its proposed rules on "Protection of Collateral of Counterparties to Uncleared Swaps; Treatment of Securities in a Portfolio Margining Account in a Commodity Broker Bankruptcy." In its letter, MFA requests that the CFTC clarify that the proposed rule explicitly requires that the custody of initial margin be pursuant to a tri-party agreement. In addition, we recommend that to ensure that segregation of collateral for uncleared swap is available on commercially reasonable terms, the CFTC should: (i) provide counterparties

The SEC approved a FINRA proposal that allows customers in FINRA arbitration to have the option of choosing an all-public arbitration panel in all cases with three arbitrators. As a result of the rule change, customers have two options for panel composition: (1) a majority-public panel and (2) an all-public panel. The rule change is effective immediately. Document Number FINRA Regulatory Notice 11-05 Date February 1, 2011 Cross References SR-FINRA-2010-053 SEC Release 34-63799 (Approval Order) Comments Received FINRA News Release FINRA Rules 12402-03

The federal bank, thrift and credit union regulatory agencies, along with the Farm Credit Administration, announced that the Nationwide Mortgage Licensing System and Registry will begin accepting federal registrations on Jan. 31, 2011. Under the Secure and Fair Enforcement for Mortgage Licensing Act (S.A.F.E. Act) and the agencies' final rules, residential mortgage loan originators employed by banks, savings associations, credit unions, or Farm Credit System institutions must register with the registry, obtain a unique identifier from the registry, and maintain their registrations. Date

OFAC is implementing policy changes announced by President Barack Obama on January 14, 2011, to allow, among other things, for greater licensing of travel to Cuba for educational, cultural, religious, and journalistic activities and to expand licensing of remittances to Cuba. Date January 28, 2011 Cross References 76 Fed. Reg. 5072 (Jan. 28, 2011)

Commentary Prof. Craig Pirrong commenting on efforts by Congress and the CFTC to deal with the problem of manipulation, states that "[t]he problem is that instead of taking a new, economics-based approach to the problem, Congress keeps returning to the vapory SEC 10(b)-5 "manipulative contrivance or device" standard, like a dog returning to its own vomit." He criticizes the CFTC position limit proposal because it (a) identified a way in which large positions could cause unwarranted fluctuations, and (b) imposed limits that were completely unnecessary to address the very problem the CFTC