Comment Letter (SIFMA) SIFMA submitted a comment letter to the SEC regarding a request from the NYSE and NASDAQ for a n exemption from the "alternative uptick rule" of Rule 201 of Reg. SHO for single-priced opening, reopening and closing transactions executed on their respective exchanges. Although the letter states that the SEC has declined to grant the requested relief, SIFMA notes the potential unintended impact of the rule and urges the SEC to reconsider its decision. Date January 19, 2011 Cross References (links may require a Cabinet subscription) Reg. SHO Rule 201

CFTC Dodd-Frank Working Group A Federal interagency working group led by the CFTC today released a report on the oversight of existing and prospective carbon markets, fulfilling a requirement established in Section 750 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The report articulates four general objectives for facilitating carbon markets, and concludes that "more detailed work may be necessary to consider the appropriate oversight regime for existing and prospective primary and secondary carbon markets, particularly if or when Congress considers Federal market-based

Financial Services Authority The FSA have published a letter to CEOs setting out 'good practices' they observed during their asset and liability management ("ALM") examinations over the last year. In the letter, the FSA expand on those observed practices and set out some suggestions. 4 key themes of the letter are: 1. The role of the senior ALM committee. The FSA review draws out the core purpose of this committee, noting that, in many firms, the committee is also responsible for designing and implementing a funds-transfer pricing mechanism. 2. The composition and authority of the senior ALM

Securities Exchange Commission The Commission will consider (i) whether to propose rule amendments that would implement Section 413(a) of the Dodd-Frank Act regarding the definition of "accredited investor", and (ii) whether to propose a rule under the Advisers Act establishing reporting obligations for advisers to private funds to implement the requirements of Sections 404 and 406 of the Dodd-Frank Act. Please contact any of the following Cadwalader attorneys if you have any questions about this item: Dorothy Mehta, [email protected]; Ed Lyon, [email protected]. Date January 18, 2011

Comment Letter (SIFMA/ISDA) SIFMA and ISDA submitted a joint comment letter to the SEC on Proposed Regulation SBSR, regarding the reporting and dissemination of security-based swap information. The letter (which is nearly 60 pages, including appendices) stresses the importance of black trade exemptions from certain of the real time public dissemination requirements of proposed Regulation SBSR, and includes a lengthy study of block trade reporting in OTC derivatives markets. In addition, the comment letter addresses, among other things, (1) consistency between the SEC rules and the rules of the