SEC Release The SEC voted to propose a rule, as required by Dodd-Frank, to govern the registration process for municipal advisors. The rule would supplant a temporary rule adopted by the SEC in September. Document Number SEC Release 34-63576 Date December 20, 2010 Cross Reference (links require a Cabinet subscription) SEC Press Release 2010-253 SEC Release 34-62824 (Temporary registration rule)

MSRB Notice The MSRB issued a notice to remind firms that its interpretive guidance on political contributions and prohibitions on municipal securities business became effective on December 12. The interpretation could result in a PAC formed by or otherwise maintaining a relationship with an affiliate of a broker, dealer, or municipal securities dealer being viewed as "controlled" being treated as a dealer-controlled PAC for purposes of MSRB Rule G-37. Document Number MSRB Notice 2010-57 Date December 17, 2010 Cross Reference (links require a Cabinet subscription) MSRB Notice 2010-45

News Article U.S. regulators have proposed lowering the bar for membership into clearinghouses, which guarantee swaps. The move would force big banks to share profits relating to OTC derivatives business with non-incumbent firms under the new regulatory regime-a business opportunity estimated to be several billion dollars, according to consultants at Booz Co. The CFTC last week voted in a proposal that derivatives clearing organizations wouldn't be permitted to set capital requirements on new members above $50 million-significantly lower than the existing hurdles. "The proposed participant

Comment Letter (SIFMA) SIFMA submitted comments to the SEC on a proposed rule that would extend temporary Rule 206(3)-3T under the Investment Advisers Act (IAA), for an additional two years beyond its scheduled expiration on Dec. 31, 2010. The rule establishes a means for broker-dealers to comply with § 206(3) of the IAA. SIFMA strongly favors an extension of Rule 206(3)-3T, arguing that the principal trading relief in the rule is more favorable to investors than dealings solely on an agency basis. SIFMA further suggests the rule should be made permanent and expanded, and reiterates its

Commentary Prof. Pirrong takes issue with the notion that improved transparency unambiguously increases competition, noting that "greater price transparency [the goal of swap execution facilites] can lead to less competitive outcomes. In particular, transparency can facilitate collusion, and opacity can make it more difficult to collude." Publication Streetwise Professor Date December 21, 2010 Cross Reference (links require a Cabinet subscription) Dodd-Frank Act, Title VII, Sec. 733.