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Financial Services Authority May 11, 2011 The FSA has published a Consultation Paper called "Strengthening Capital Standards 3: further consultation on CRD3". The financial crisis demonstrated that the current market risk framework fails to adequately capture some important risks in firms' trading books. In response, the Basel Committee on Banking Supervision (BCBS) decided it was necessary to increase the risk capture and level of capital requirements in the trading book and credit risk and illiquidity in the trading book. The CRD changes implement these requirements in Europe and will result

FIA Comment Letter RIN 3038-AD50 May 10, 2011 FIA submitted a comment letter responding to the CFTC's notice of proposed rulemaking relating to the registration of intermediaries. The FIA letter expressed its support for a provision in the proposal that exempts foreign brokers who submit for clearing over-the-counter transactions that have been executed on a swap execution facility. FIA suggested this exemption be expanded to cover cleared bilateral transactions. Further, FIA urged the CFTC to confirm that associated persons of futures commission merchants would be exempt from being registered

CFTC Speeches May 11, 2011 "NOT ALL END-USERS ARE CREATED EQUAL" Commissioner Scott O'Malia expresses concerns regarding the margin and capital rules as they interact with the definition of swap dealer. He observes that many of the comments related to the proposed definition echo "a recurring theme: the definition is too broad and the exceptions are too narrow. Unfortunately, our proposal captures legitimate commercial end-users as swap dealers." On capital and margin requirements for end-users, O'Malia states that "there is no doubt that the cost for end-users in all categories to hedge their