SEC Release (Rulemaking) The SEC is requesting public comment on a study it is conducting, pursuant to § 939(h) of the Dodd-Frank Act, on the feasibility and desirability of standardizing credit ratings terminology. Document Number SEC Release 34-63573 Date December 17, 2010 Cross Reference (links require a Cabinet subscription) Dodd-Frank § 939(h)

CFTC Dodd‑Frank Rulemaking The CFTC is proposing new rules and amended guidance and acceptable practices to implement the new statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act that, among other things, amends Section 5 of the CEA concerning designation and operation of contract markets, and adds a new CEA Section 2(h)(8) to include the listing, trading and execution of swaps on designated contract markets. The proposed rule takes up 66 pages of the Federal Register. Document Number 75 Fed. Reg. 80572 Date December 22, 2010 Cross

News Article In a recent speech, Richard Ketchum, chief executive of FINRA, said that high-frequency trading firms should expect greater surveillance of their operations in 2011. In particular, Mr. Ketchum cited a recent enforcement action brought by FINRA against Trillium Brokerage Services as a "good example" of what to expect. Please contract the following Cadwalader attorneys if you have any questions about this item: Steven Lofchie; [email protected] Glen Barrentine; [email protected] Publication The Wall Street Journal Date December 20, 2010 Cross Reference (links require a

CFTC Dodd‑Frank Rulemaking The CFTC is proposing for comment new rules under Section 4s(h) of the CEA to implement provisions of Title VII of the Dodd-Frank Act relating generally to external business conduct standards for swap dealers and major swap participants. Document Number 75 Fed. Reg. 80638 Date December 22, 2010 Cross Reference (links require a Cabinet subscription) Dodd-Frank Act, Title VII, Sec. 731 New CEA Sec. 4s(h) 17 CFR Parts 23 and 155

News Article U.S. regulators this week are considering rules aimed at curbing speculation in commodities trading, as Wall Street firms call for delay and companies including Delta Airlines Inc. urge strict limits. Publication Bloomberg/Businessweek Date December 22, 2010 Cross Reference (links require a Cabinet subscription) Dodd-Frank Act, Title VII, Sec. 737