www.isda.org ISDA has submitted comments in response to the CFTC proposed rules to implement Section 724(c) of the Dodd-Frank Act. In general, ISDA's comments reflected that the rules should permit bilateral contract negotiation in place of formalistic rules where appropriate should strike a balance between the burden presented and the need to protect the interests of counterparties who are, by definition, deemed to be able to protect their own interests. Date February 1, 2011 Cross References 724(c) of the Dodd-Frank Act

www.isda.org ISDA's Accounting Policy Committee has published a comment letter on the IASB's Request for Views on Effective Dates and Transition Methods. ISDA's main points are (1) a preference for a single mandatory date for adoption of the standards described in the Request for Views; (2) the mandatory date of adoption should be no earlier than January 1, 2015, (3) entities should have the ability to adopt standards earlier if they have the ability to do so and (4) the exemption from restating comparative information should be extended to all entities that adopt a standard prior to the

www.isda.org ISDA has commented on the IASB and FASB proposals on US GAAP and IFRS models regarding offsetting of assets and liabilities in the balance sheet. ISDA believes that the' proposal to report derivatives on a gross basis rather than a net basis on the balance sheet is counterintuitive, may lead to complexity in practice and can obscure the real position of the entity. Date January 31, 2011 Cross References IFRS

The FDIC has announced a series of steps intended to provide regulatory relief to financial institutions and facilitate recovery in areas of California affected by severe winter storms, flooding, debris, and mud flows. Date January 28, 2011 Cross References FIL-3-2011

CFTC Speeches Speech of Commissioner Bart Chilton to the American Public Gas Association Winter Conference. In this speech, Commissioner Chilton returns to his familiar and favorite themes--blaming "massive passives" (large passive index funds), algorithmic trading, and unregulated swaps for the financial markets ills of the past few years. Date January 31, 2011 Cross References Dodd-Frank Act, Title VII