The Joint Administrators of Lehman Brothers International (Europe) have published a series of changes to the Claim Resolution Agreement. The goal of these modifications is to facilitate the sending of Claim Amount Notices, as the amendments mean that to do so will not pre-empt the right of Signatories to raise Disputes. Date January 27, 2011

Comment letter MFA submitted a comment letter to the CFTC in response to its proposed rules on "Protection of Collateral of Counterparties to Uncleared Swaps; Treatment of Securities in a Portfolio Margining Account in a Commodity Broker Bankruptcy." In its letter, MFA requests that the CFTC clarify that the proposed rule explicitly requires that the custody of initial margin be pursuant to a tri-party agreement. In addition, we recommend that to ensure that segregation of collateral for uncleared swap is available on commercially reasonable terms, the CFTC should: (i) provide counterparties

According to a report in InvestmentNews, FINRA CEO Richard Ketchum has indicated that a fiduciary standard for brokers is unlikely to occur before mid-2012. Mr. Ketchum made the comments at a recent speech before the Financial Services Institute, in which he outlined the potential administrative path toward a fiduciary standard for brokers. Publication Investment News Date February 1, 2011 Cross References SEC Staff Study on Investment Advisers and Broker-Dealers Dodd-Frank § 913

News Article Republican lawmakers aiming to rein in the federal budget have asked U.S. agencies implementing the Dodd-Frank financial-rules overhaul to provide a full account of their spending, hiring and contracting. House Financial Services Committee Chairman Spencer Bachus and Representative Randy Neugebauer have asked nine agencies, including the Treasury Department, SEC, and CFTC to lay out the new law's effect on their fiscal 2011 budget requests. "It is our responsibility to ensure that mandates are not overly burdensome or wasteful of taxpayer money," Bachus and Neugebauer, who leads

www.isda.org ISDA has published a comment letter on the European Commission document "Green Paper from the Commission on policy options for progress towards a European Contract Law for consumers and businesses" issued on 1 July 2010. ISDA's comments include (among other things) that ISDA does not believe that it is necessary or appropriate for a European instrument on contract law aspects to become mandatory in any way and that ISDA urges the Commission to ensure that the choice of the law governing the contract remains solely up to both counterparties to a transaction. Date January 31, 2011