February 9, 2011 The Federal Reserve Board on Wednesday announced its approval of a final rule to implement the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that give banking firms a period of time to conform their activities and investments to the prohibitions and restrictions of the so-called Volcker Rule.

File No. S7-18-08 February 9, 2011 SEC Proposes the first in series of amendments to Rules and forms to remove references to credit ratings. Cross References Rules 134, 138, 139, and 168, under the Securities Act; Forms S-3, S-4, F-3, F-4, and F-9. Schedule 14A under the Securities Exchange Act.

SEC Release 33-9186 / 34-63874 February 9, 2011 The SEC proposed rule amendments that, in accordance with § 939A of Dodd-Frank, would remove credit ratings as one of the conditions for companies seeking to use short-form registration when registering securities for public sale. Instead of ratings, the new short-form test for shelf-offering eligibility of companies would be tied to the amount of debt and non-convertible securities they have sold in the past three years. Cross References SEC Press Release 2011-41 Dodd-Frank § 939A Securities Act Rule 134 SEC Forms S-3, F-3, F-9

NYSE Euronext No-Action Letter February 7, 2011 The SEC Division of Market Regulation granted exemptive relief under Rule 201 of Regulation SHO to the NYSE to use certain reference prices other than the national best bid in determining whether a short sale order in a covered security that has triggered Rule 201's circuit breaker can be executed in a "single-priced opening, reopening, or closing transaction" executed on the NYSE (or NYSE Amex). Cross References Regulation SHO, Rule 201 SIFMA Letter to SEC (Jan. 19, 2011) (requesting same exemptive relief)

CFTC Dodd-Frank Rulemaking 76 Fed. Reg. 6715 February 8, 2011 Closing Date for Comments: April 11, 2011 The proposed rules would establish requirements for swap trading relationship documentation for swap dealers and major swap participants. The rule is being proposed pursuant to Section 731 of the Dodd-Frank Act added a new section 4s(i) to the Commodity Exchange Act, which requires the Commission to prescribe standards for swap dealers and major swap participants related to the timely and accurate confirmation, processing, netting, documentation, and valuation of swaps. Cross References Dodd