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On July 5, 2011, the FDIC, FRB, OCC and OTS (collectively the "Agencies") jointly issued guidance (the "Guidance") to clarify supervisory expectations and sound practices for an effective counterparty credit risk ("CCR") management framework.

The North American Securities Administrators Association ("NASAA"), a voluntary organization of securities agencies across the United States, Canada and Mexico, has released a revised version of its proposed model rule (the "Revised Proposal") that would generally exempt investment advisers from the obligation to register at the state level, if the advisers: (i) are not subject to disqualification based upon their prior disciplinary history; and (ii) solely advise funds that are excluded from th