In This Issue:

Conflicts of Interest; Volcker Rule; SEC’s Staff Legal Bulletin on Legal Opinions; Focus on ETFs/ETNs; and Revised FINRA Proposal Applies Content Standards of Rule 2210 to Broadly Disseminated FWPs.

Except from Conflicts of Interest

On September 19, 2011, the Securities and Exchange Commission (“SEC”) released a proposed rule (“Proposed Rule 127B”) implementing the conflicts of interest provisions of Section 621 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). Section 621 added a new section 27B to the Securities Act of 1933, as amended (the “Securities Act”). Proposed Rule 127B was released on September 19, 2011, for a 90-day comment period, which will end on December 19, 2011.