SEC Release (Nasdaq Rulemaking) The SEC declared immediately effective a Nasdaq proposal to reduce the costs of executing trades and providing "depth of book" data products for Nasdaq firms that service "non-professional" (retail) users with which the firm has a brokerage relationship. The filing is intended to address a concern that retail orders are increasingly being executed by internalizers (i.e. off exchanges), and thus lacking pre-trade transparency, exposure, or order interaction. The filing contains a lengthy discussion from Nasdaq as to competition in the market for transaction

International Swaps and Derivatives Association ISDA publishes Standard Terms Supplement and Confirmation for Syndicated Secured Loan Contingent Credit Default Swap Transaction. Date January 21, 2011 Cross References (links may require a Cabinet subscription) Single Name CDS Swaption Standard Terms Supplement Credit Default Swaption Confirmation

Commentary Prof. Craig Pirrong critiques CFTC position limit proposal as "a good example of bad regulation . . . [that] inflicts harm on 'massive passives,'" i.e., pension funds and ETFs "even though they do not pose the risks that the Commission uses to justify the imposition of limits." Publication Streetwise Professor Date January 24, 2011 Cross References (links may require a Cabinet subscription) Dodd-Frank Act, Title VII, Sec. 737

SEC Release (Enforcement) The SEC announced a settled administrative proceeding against a UK-based investment advisor for a violation of Rule 105 of Regulation M. The release alleges that the firm sold short common stock of a company in the five days prior to receiving shares in a secondary offering of the securities. Document Number SEC Release 34-63757 / IA-3143 Date January 24, 2011 Cross References (links may require a Cabinet subscription) Regulation M, Rule 105

News Article Article noting the link between higher commodity prices and the political push in the U.S. to impose position limits to mitigate those prices. The article quotes Tom LaSala, chief regulatory officer at the Chicago Mercantile Exchange, as stating that the CFTC proposal represented a step in the wrong direction: "Position limits do have a place - CME Group employs position limits in its agricultural commodities, as well as a combination of position limits and position accountability standards in its energy and metals contracts. "Rather than hard limits, we believe exchange-position