Euroclear March 2011 Euroclear have published a guide aimed at helping CREST members meet both their own MiFID FSA transaction reporting obligations and any reporting agent responsibilities they have to others. It explains how Euroclear UK Ireland, in its role as an Approved Reporting Mechanism (ARM), will interpret transaction reports made by CREST member firms to using the CREST system for onward reporting to the FSA (the 'ARM service').

Futures Industry Association Comment Letter RIN 3038-AD15 and 3038-AD16 March 25, 2011 The FIA on March 25 submitted a detailed response to the CFTC's proposed rulemaking on speculative position limits. Although the FIA continues to oppose implementation of hard limits and continues to challenge the view that speculative investments have caused an increase in commodity prices, the FIA set out a number of specific recommendations for revising the proposed rule. The FIA also expressed its appreciation for the CFTC's decision to adopt a two-phase approach to the imposition of position limits

British and Irish Legal Information Institute The High Court's judgment in Bank Leumi (UK) plc v Wachner (Linda Joy) [2011] EWHC 656 (Comm) (22 March 2011) has been published. In the judgement, the Commercial Court dismissed Ms Wachner's counterclaims against Bank Leumi (BLUK) in relation to alleged misrepresentations and negligent advice about certain foreign exchange options, and that BLUK had misclassified her under the FSA's Code of Business Rules (COB) and/or its successor the Conduct of Business Sourcebook (COBS).

www.isda.org March 29, 2011 ISDA has published a paper outlining its views on the role, impact and optimal structure for Swap Execution Facilities (SEFs) in the global OTC derivatives markets. ISDA believes that SEFs can play a positive role in the market by strengthening its infrastructure, helping prevent insider trading and other market abuse, and increasing transparency and access for smaller participants.

www.isda.org March 25, 2011 The North American Tax Committee of ISDA has published a comment letter on selected issues relating to regulations to be issued by the Treasury Department pursuant to Section 871(m) of the Internal Revenue Code of 1986, as amended. The NATC's primary concern is the manner in which the Treasury may define the categories of transactions that are treated as specified notional principal contracts ("SNPCs") and that will be subject to withholding taxes on "dividend equivalent payments." Cross References Section 871(m) of the Internal Revenue Code of 1986, as amended