International Monetary Fund March 26, 2011 Recent regulatory efforts, especially in the U.S. and Europe, are aimed at reducing moral hazard so that the next financial crisis is not bailed out by tax payers. This IMF paper looks at the possibility that central counterparties (CCPs) may be too-big-to-fail entities in the making. The present regulatory and reform efforts may not remove the systemic risk from OTC derivatives but rather shift them from banks to CCPs. Under the present regulatory overhaul, the OTC derivative market could become more fragmented. Furthermore, another taxpayer bailout

MFA Comment Letter RIN: 3038-AD15 and 3038-AD16 March 28, 2011 MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains concerned that the CFTC's proposal is not empirically driven and that it may place a greater burden on interstate commerce by hindering the ability of futures markets to perform their fundamental price discovery, risk transfer and risk management functions. MFA is especially concerned that the proposal will result in unnecessary aggregation of independently controlled accounts, burden investors and investment

CFTC Dodd-Frank Rulemaking March 29, 2011 The Commodity Futures Trading Commission has cancelled its open meeting on Thirteenth Series of Proposed Rules under the Dodd-Frank Act scheduled for Wednesday, March 30, 2011. Cross References Dodd-Frank Act, Title VII

FINRA Targeted Examination Letter March 28, 2011 FINRA posted on its website a "targeted examination letter," requesting that firms provide to FINRA all "advertisements, sales literature, and institutional sales material" that concern reverse exchangeable securities (reverse convertibles), as well as firms' relevant supervisory procedures, offering documents relating to reverse convertibles, and certain other relevant material. Firms are required to submit this information to FINRA by April 1, 2011. Cross References NASD Rule 2210, 2211

Financial Services Authority Last year, the FSA published proposals for improving the quality of governance within firms and the intensity of their supervisory regime. The FSA had expected that firms would submit applications on behalf of individuals to perform new SIFs via the FSA's Online Notifications and Applications (ONA) system. However, there is currently a considerable programme of work underway on ONA and the FSA have been unable to complete the necessary changes to allow them to accept applications and notifications from 1 May 2011. Consequently, the FSA are deferring the