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The CFTC Division of Market Oversight issued a letter providing swap dealers with time-limited no-action relief from swap data reporting obligations with respect to equity swaps, foreign exchange swaps and other commodity swaps. The letter provides swap dealers with reporting relief (i) under CFTC Rules Part 43 [Real-Time Public Reporting] and Part 45 [Swap Data Recordkeeping and Reporting Requirements] until February 28, 2013, and (ii) under CFTC Rule Part 46 [Swap Data Recordkeeping and Reporting Requirements: Pre-Enactment and Transition Swaps] until March 30, 2013. The footnotes to the

The SEC is amending Exchange Act Rules 19b-4(n)(1) and 19b-4(o)(2) to extend the dates for certain requirements therein, and amending the General Instructions to Form 19b-4 to clarify the process by which SEC-registered clearing agencies submit plans to accept security-based swap for clearing to the Commission. This is being done to prevent scenarios in which such filings are required to be filed with the SEC through a system that is not yet technologically able to accept them. Effective Date: December 10, 2012. Cross-Reference(s): Dodd-Frank Sections 763 (Amendments to the Securities Exchange

A coalition of four trade associations has joined together to challenge a rule issued by the SEC that requires public companies to disclose payments of more than $100,000 made to foreign governments for projects relating to the commercial development of oil, natural gas, or minerals. The associations (including the U.S. Chamber of Commerce, the American Petroleum Institute, the Independent Petroleum Association of America and the National Foreign Trade Council) are challenging the SEC’s "Disclosure of Payments by Resource Extraction Issuers" rule, also known as "extractive industries rule,"

Federal Reserve Governor Daniel K. Tarullo gave a speech discussing the industrial organization ("IO") of the financial industry, including how research could potentially apply to Dodd-Frank rulemaking and regulatory policy. Governor Tarullo surveyed various proposals directed at the "too-big-to-fail" problem in financial markets, and summarized the arguments surrounding those proposals from both a policy and IO perspective. The proposals he discussed were (i) breaking up large financial institutions by reinstating Glass-Steagall restrictions or imposing other affiliation prohibitions; (ii)