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FIA, ISDA, SIFMA FIA, ISDA, and SIFMA filed a joint letter on Jan. 18 commenting on two proposed rules issued by the CFTC. The proposed rules are aimed at preventing conflicts of interest at futures commission merchants, introducing brokers, swap dealers and major swap participants. The associations offered a number of suggestions relating to the CFTC's proposed rules regarding conflicts of interest related to research, and also commented on proposed rules regarding conflicts of interest related clearing services Date January 18, 2011 Cross References (links may require a Cabinet subscription)

Independent Commission on Banking The Independent Commission on Banking was created by the UK government in June 2010 and is chaired by Sir John Vickers. The Commission's role is to consider reforms relating to the capital and corporate structure of the UK banking sector to promote financial stability and competition. On 22 January 2011 Sir John Vickers made a speech at the London Business School about the Commission's work. He put forward two questions to be addressed by the Commission in its review: (i) whether, and if so how, structural reform of systemically-important institutions might

International Swaps and Derivatives Association ISDA has submitted comments in response to he proposed regulations CFTC in accordance with section 4s of the CEA (added to the CEA by the Dodd-Frank Act,, with respect to the registration of swap dealers and major swap participants. Date January 24, 2011 Cross References (links may require a Cabinet subscription) Section 4s of the CEA

Securities Exchange Commission The SEC has voted to propose amendments to the accredited investor standards in its rules under the Securities Act to reflect the requirements of Section 413(a) of the Dodd-Frank Act. The proposed amendments would exclude the value of an individual's primary residence in calculating net worth when determining accredited investor status. The amendments also would clarify the treatment of any indebtedness secured by the residence in the net worth calculation. Document Number File No. S7-04-11 Date January 25, 2011 Cross References (links may require a Cabinet

SEC Release (Enforcement) The SEC announced a settled administrative proceeding against a Merrill Lynch entity for allegedly (1) misusing customer order information to place proprietary trades and (2) charging customers undisclosed trading fees. The order alleges that a proprietary trading desk at ML traded on information gained from institutional customer orders at ML's market making desk. In addition, the order alleges that ML charged some customers markups or markdowns when it represented that it would only charge a commission equivalent to executing riskless principal trades. Notably, the