SEC Release No. 33-9204 / 34-64372 April 29, 2011 The SEC and CFTC, in consultation with the Fed, published a joint proposal to further define the terms "swap," "security-based swap," and "security-based swap agreement." Among other things the proposal would, (1) exclude certain insurance products from the definitions of swap and security-based swap; (2) exclude certain consumer and commercial transactions (such as consumer loans and mortgages, property leases, and warehouse lending arrangements) from the definitions of swap and security-based swap; (3) distinguish types of products are "swaps

US Dept. of Treasury Dodd Frank Rulemaking Fact Sheet Fed. Reg. Release April 29, 2011 The Treasury Department on April 29 issued a "notice of proposed determination" exempting foreign exchange swaps and forwards from the central clearing and exchange trading requirements of the Dodd-Frank Act. "The FX swaps and forwards market is markedly different from other derivatives markets," Treasury stated in a fact sheet published on its website. Treasury noted, however, that even if the products are exempted from the clearing and trading requirements, they will remain subject to Dodd-Frank's new

SEC No-Action Letter April 7, 2011 The SEC granted Wells Fargo no-action relief under Rule 405 from being considered an "ineligible issuer" due to an SEC order regarding disclosure and sales practices relating to certain CDOs. Cross References Securities Act Rule 405

CFTC 76 Fed. Reg. 24464 May 2, 2011 The CFTC is calling for nominations to the Subcommittee on Data Standardization under the auspices of the Technology Advisory Committee. The Subcommittee was established to develop recommendations for a standardized reference data depository representing the universe of legal and financial terms utilized in describing, defining, and valuing the various derivatives and other financial instruments which are presently and in the future may be traded on and off of regulated exchanges. The Subcommittee will report to the full Technology Advisory Committee.

International Swaps and Derivatives Association April 29, 2011 ISDA submitted comments on the SEC notice of proposed rulemaking Clearing Agency Standards for Operation and Governance addressing clearing member eligibility, default procedures, margin requirements, and settlement requirements. Cross References Dodd-Frank Section 763; Dodd-Frank Section 805; Securities Exchange Act Section 17A