Comment Letter (SIFMA) SIFMA submitted a comment letter to the SEC regarding a request from the NYSE and NASDAQ for a n exemption from the "alternative uptick rule" of Rule 201 of Reg. SHO for single-priced opening, reopening and closing transactions executed on their respective exchanges. Although the letter states that the SEC has declined to grant the requested relief, SIFMA notes the potential unintended impact of the rule and urges the SEC to reconsider its decision. Date January 19, 2011 Cross References (links may require a Cabinet subscription) Reg. SHO Rule 201

CFTC Dodd-Frank Working Group A Federal interagency working group led by the CFTC today released a report on the oversight of existing and prospective carbon markets, fulfilling a requirement established in Section 750 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The report articulates four general objectives for facilitating carbon markets, and concludes that "more detailed work may be necessary to consider the appropriate oversight regime for existing and prospective primary and secondary carbon markets, particularly if or when Congress considers Federal market-based

SEC Press Release (Enforcement) The SEC announced the filing of a civil complaint against a Costa Rican company that provides financial guarantee bonds on life settlements. The complaint alleges that the company and its "purported" outside auditor misrepresented the company's ability to satisfy its obligations under the bonds. The complaint charges the defendants with violations of the anti-fraud provisions of the Securities Act and Exchange Act. In addition, criminal charges were filed in the matter. Document Number SEC PR 2011-15 Date January 19, 2011 Cross References (links may require a

NFA Amendments to NFA Financial Requirements Sections 11(b), 14(c) and (d), and the related Interpretive Notice to become effective February 1, 2011. NFA Financial Requirements Section 11(b) and (c) inter alia prohibit a Forex Dealer Member (FDM) from including assets as current for purposes of determining adjusted net capital and from using those assets to cover currency positions if the assets are held at an affiliate or an unregulated person. An unregulated person is defined by the rule to include any entity except those specifically excluded. Document Number Notice to Members I-11-03 Date

EuropeanIssuers On 14 January 2011, European Issuers', a pan European organisation, published its response to the European Commission's Consultation Paper on Credit Rating Agencies of 5 November 2010. European Issuers stated: the measures designed to prevent another financial crisis should not be applicable to all corporates as issuers of corporate bonds were not the cause of the financial crisis and consequently should not be penalised; opposition to the extension of the right of access to business information to other credit rating agencies other than that hired by an issuer; and preference