CFTC PR 6026-11 April 27, 2011 The CFTC held a public meeting on Wednesday, April 27, 2011 to consider the issuance of proposed rulemakings under the Dodd-Frank Wall Street Reform and Consumer Protection Act on the following topics: Capital Requirements of Swap Dealers and Major Swap Participants; Protection of Cleared Swaps Customer Contracts and Collateral and Conforming Amendments to the Commodity Broker Bankruptcy Provisions; Product Definitions Contained in Title VII of the Dodd-Frank Act; and Amendments to Adapt Certain CFTC Regulations to the Dodd-Frank Act. Opening Statements Opening

SEC Release No. 34-64352 April 27, 2011 Pursuant to a requirement under Dodd-Frank, the SEC published a proposal to amend a number of Exchange Act rules to remove references to credit ratings in those rules. The proposal principally would amend four rules: Rule 15c3-1 (Net Capital) would be amended to, among other things, require firms to take a 15% haircut on proprietary positions in convertible paper, nonconvertible debt, and preferred stock unless a firm has a process in place for assessing creditworthiness that satisfies the new rule. As currently required, however, a 100% haircut would

CFTC Speeches April 26, 2011 Commissioner Sommers talks about the broad scope of statutory definitions of swap dealer, etc. under Dodd-Frank and the "very limited" exemptions being proposed. "While only a handful of entities will likely be classified as major swap participants, the breadth of the proposed swap dealer definition will capture many participants that in my opinion should not be considered dealers. Moreover, the de minimus exemption is so narrow that it is unlikely to have much utility." She also discusses the extraterritorial application of Dodd-Frank that threatens to involve

British and Irish Legal Information Institute April 20, 2011 The British Bankers' Association ("BBA") has failed in its attempt to obtain a judicial review of the FSA regulations governing the sales of payment protection insurance ("PPI"); a type of loan insurance which covers debt repayments if a borrower is unable to work due to an accident, illness or period of unemployment. In October 2010, British banks, represented by the BBA, had requested a judicial review to examine changes in the way banks were permitted to sell loan cover. British banks claimed that the new FSA rules were being used

Study and Recommendations on Section 404(b) of the Sarbanes-Oxley Act of 2002 For Issuers With Public Float Between $75 and $250 Million April 22, 2011 The SEC published a study it submitted to Congress, as required by the Dodd-Frank Act, regarding ways to reduce the burdens imposed by § 404(b) of the Sarbanes-Oxley Act on issuers with a public float between $75 and $250 million. The study sets forth two principal goals: (1) maintaining current investor protections of § 404(b) for accelerated filers; and (2) encouraging activities to improve the "effectiveness and efficiency" of § 404(b)