With Robert Ledig, George Mazin
The Commodity Futures Trading Commission and Securities and Exchange Commission on January 26, 2011, jointly proposed new rules (collectively "Proposed Rules") under the Commodity Exchange Act ("CEA") and the Investment Advisers Act of 1940 ("Advisers Act") to implement provisions of Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act") that require systemic risk reporting by registered investment advisers, commodity pool operators ("CPOs") and com