March 29, 2011 In a paper published on March 29 th, the International Swaps and Derivatives Association, Inc. outlined its views on the role, impact and optimal structure for Swap Execution Facilities in the global over-the-counter derivatives markets. Cross References Dodd-Frank Act, Title VII, Sec. 733

www.isda.org March 28, 2011 ISDA has published a comment letter in connection with the draft amendment to the Government Ordinance no. 9/2004 regarding financial collateral arrangements to transpose into Romanian law the Directive 2009/44/EC of the European Parliament and Council of 6 May 2009 Amending the Settlement Finality and Financial Collateral Directives (2009/44/EC).

FINRA RN 11-14 March 29, 2011 FINRA published a regulatory notice to request comment on proposed FINRA Rule 3190 to govern firms' obligations and supervisory responsibilities regarding outsourcing arrangements. The new rule would state that (1) when a firm outsources a function related to its business as a broker-dealer, it remains obliged to comply with applicable securities laws and SRO rules; and (2) firms may not delegate responsibilities for, or control over, any outsourced functions. In addition, the rule would require firms to have supervisory procedures and due diligence measures to

March 28, 2011 SIFMA submitted a lengthy comment letter to FINRA regarding its recent proposal in RN 11-08 to adopt new rules on markups, commissions, and fees. Primarily, SIFMA supports the withdrawal of the 5% policy, but questions how the new rule would apply absent any clear guiding principles from FINRA. In addition, SIFMA argues that (1) FINRA should further expand the "QIB Exemption" relating to debt markups, (2) FINRA should provide further guidance on debt markups, given the "continued uncertainty and implementation difficulties under current IM-2440-2," and (3) the proposed retail

REMEC Liquidating Trust March 28, 2011 The SEC Division of Corporation Finance granted no-action relief from the registration and reporting requirements under Exchange Act § 12(g) to a trust that was established in connection with completing the liquidation of REMEC, Inc. Cross References Incoming Letter Exchange Act § 12(g)