International Swaps and Derivatives Association ISDA has published two independent studies on transparency in the OTC equity derivatives market: a paper describes the structure, participants, products and existing forms of pre- and post-trade transparency and a quantitative study which analyzes differences in pricing amongst dealers and between dealers and end-users. Generally, the paper concludes that the industry has moved towards increased post-trade regulatory transparency. The statistical study showed that the end-users trading with dealers are not at an informational disadvantage. Date

International Swaps and Derivatives Association ISDA has commented on the regulations proposed by the Commodity Futures Trading Commission with respect to the registration of swap dealers and major swap participants. Amongst other issues, ISDA has given its views on the planned implementation process, the applicability of registration requirements outside of the USA, and the definition of "associated persons" of swaps entities.

The federal banking regulators are seeking comment on a notice of proposed rulemaking (NPR) that would revise their market risk capital rules. Date January 12, 2011 Cross References (links may require a Cabinet subscription) OCC 2011-3

News Article In a forthcoming filing with the CFTC previewed on his website, Professor Craig Pirrong, one of the world's leading authorities on commodity trading, launched a spirited attack on the proposed new limits. Pirrong warns the plans are "fundamentally flawed". They go far beyond what is necessary to meet the CFTC's legitimate concerns and would constrain legitimate trading activity and market liquidity, raising costs to all market users. "There are less intrusive and expansive policies that would address the real concerns that the Commission has raised, but which would not interfere

This SR letter provides direction to supervisory and banking organization staff on the potential impact of high-cost credit protection transactions on their assessment of a banking organization's overall capital adequacy. Date January 25, 2011 Cross References (links may require a Cabinet subscription) SR 11-1