SEC Release No. 34-64191; SR-DTC-2010-15 April 5, 2011 The SEC approved a DTC proposal to remove a requirement that transfer agents that use its Fast Automated Securities Transfer ("FAST") program must maintain a balance certificate for exchange-listed issues that participate in the direct registration system. Cross References SEC Release No. 34-63320 (proposal)

SEC Release No. 34-64196 April 6, 2011 The SEC approved a rule proposal by the Options Clearing Corporation that seeks to provide clarification regarding the regulatory capital treatment under Exchange Act Rule 15c3-1 of collateral and margin posted by clearing members participating in stock loan transactions through OCC's Stock Loan/Hedge Program or Market Loan Program. The OCC program allows firms to submit broker-to-broker stock loan transactions to OCC for clearance. Cross References SEC Release No. 34-63623 (proposal) Exchange Act Rule 15c3-1

FIA ISDA RIN 3038-AD21 April 1, 2011 FIA and ISDA File Comment Letter on Commodity Options and Agricultural Swaps (April 1, 2011) FIA and ISDA filed a joint letter on April 1 commenting on the CFTC's proposed rule on the regulation of commodity options and agricultural swaps that are traded over-the-counter. The two associations expressed support for the proposal to apply the same rules to agricultural swaps that apply to all other OTC commodity derivatives under the Dodd-Frank Act, rather than applying separate or more restrictive rules to these products, and to treat agricultural trade

FINRA RN 11-16 April 7, 2011 FINRA published a regulatory notice to clarify the margin treatment for non-margin eligible equities under Regulation T. Pursuant to authority under FINRA Rule 4210(f)(8)(A)(ii), FINRA stated that maintenance margin for such securities held long in a Reg. T margin account shall be 100% of current market value. For short positions the requirements of RN 09-53 continue to apply for Reg. T accounts, but portfolio margin accounts will be subject to new specified requirements. In addition, the notice clarifies the treatment of non-margin eligible equities with respect

CFTC No-Action Letter 11-01 March 22, 2011 The Division of Clearing and Intermediary Oversight provided no-action relief to the general partners of two commodity pools from registering as CPOs under Section 4m(1) of the Commodity Exchange Act, and allowed an affiliated, registered CPO ("designee") to serve as the CPO of the pools instead, where, among other things: (1) the general partners and the designee are under common ownership and control; (2) the general partners have delegated all of their management authority to the designee; (3) the general partners do not engage in the solicitation