FINRA AWC Letter No. 20110259827-01 May 2, 2011 FINRA announced that it has barred a former representative of an Illinois-based broker-dealer for engaging in insider trading and failing to truthfully respond to questioning by FINRA investigators. The action alleges that the representative knowingly traded on the basis of insider information, and then falsely testified to FINRA that he did not know anyone currently or formerly employed at the company in whose shares he traded. Cross References FINRA News Release FINRA Rules 2010, 2020, 8210 Exchange Act Rule 10b-5 Exchange Act § 10(b)

FINRA RN 11-20 May 2, 2011 FINRA published a regulatory notice to announce that May 16, 2011 will be the effective date of amendments to the FINRA rules that subject asset-backed securities, mortgage-backed securities, and other similar securities to trade reporting through TRACE and the fees associated with it. Cross References FINRA Rule 6700 Series (TRACE Rules) FINRA Rule 7730 SEC Release No. 34-64364 (approving rule amendments) SEC Release No. 34-64041 (approving fee amendments) SEC Release No. 34-61566 (approving rule changes subjecting ABS to TRACE)

European Union April 29, 2011 The Council of the EU have published a Presidency compromise proposal, in particular with a view to discussions at the meeting of the Working Party of Financial Services AttachÉs on 3 May. Additional detail is given regarding payment systems, and the calculating of dates for when clearing obligations take effect. Most other changes are clean-up in nature, and are not substantive.

SEC Release No. 34-64374 / IA-3191 May 2, 2011 The SEC published a settled administrative action against a New York-based hedge fund manager alleged to have violated Rule 105 of Regulation M. The release alleges that the firm, on four occasions, purchased shares from an underwriter or offering participant in a follow-on public offering after having sold the relevant security short during the restricted period. The action resulted in a $400,000 civil penalty and over $1 million in disgorgement. Cross References Reg. M, Rule 105

Bank of America Corp., SEC No-Action Letter April 29, 2011 The SEC staff granted relief to Bank of America Corp. (BAC) under Section 30(h) of the Investment Company Act in connection with the sale of certain variable rate demand preferred shares of closed-end investment companies which may cause BAC to have a greater than 10% equity stake in the investment companies. By its terms, Section 30(h) would subject such BAC to the reporting requirements of Section 16(a) of the Exchange Act. In granting relief, the SEC noted that the transactions in which BAC is entering would not provide the firm