Consilium February 21, 2012 The Council of the European Union has adopted a Regulation on short selling and certain aspects of credit default swaps which introduces common EU transparency requirements and harmonises the powers that regulators may use in exceptional situations where there is a serious threat to financial stability. Cross References: Version of text to be adopted Press Release: Short selling: more transparency and stricter rules

International Swaps and Derivatives Association February 15, 2012 ISDA has published a paper on the nature of trading structures and liquidity formation in OTC derivatives markets and the associated implications under MIFID2/MIFIR. The publication makes the following recommendations: (i) a redraft or replace Article 7 of MiFIR to accommodate trading systems other than order book systems without relying on the waiver process; and (ii) the removal of the quote-sharing obligation from Article 17.

FINRA Reg. Notice 12-14 FINRA seeks comment on a revised proposal to amend NASD Rule 2340 (Customer Account Statements) to address the per share estimated values at which unlisted Direct Participation Programs (DPPs) and unlisted Real Estate Investment Trusts (REITs) are reported on customer account statements. The revised proposal reflects changes based on comments to the amendments FINRA proposed in Regulatory Notice 11-44. Under the revised proposal, general securities members would no longer be required to provide a per share estimated value, unless and until the issuer provides an

CFTC SEC Joint Release 77 FR 13450 The CFTC and the SEC are jointly issuing proposed rules and guidelines to implement new statutory provisions enacted by Title X of the Dodd-Frank Act. These provisions amend section 615(e) of the Fair Credit Reporting Act and direct the CFTC and SEC to prescribe rules requiring entities that are subject to their jurisdiction to address identity theft in two ways. First, the proposed rules and guidelines would require financial institutions and creditors to develop and implement a written identity theft prevention program that is designed to detect, prevent

FINRA Reg. Notice 12-13 The SEC approved FINRA's proposed rule change to adopt FINRA Rules 5310 (Best Execution and Interpositioning) and 6438 (Displaying Priced Quotations in Multiple Quotation Mediums) in the consolidated rulebook (Consolidated FINRA Rulebook). FINRA Rule 5310 is the new consolidated rule governing members' best execution requirements that is based largely on NASD Rule 2320 (Best Execution and Interpositioning). The Supplementary Material to Rule 5310 draws substantially from NASD IM-2320 (Interpretive Guidance with Respect to Best Execution Requirements) but includes