There is a summary of applicable rules on the Ofcom website. Recording is sometimes advised, as in recording business transactions carried out by telephone to provide a record. It is sometimes mandatory; from March 2009 Financial Services Authority rules required firms to record all telephone conversations and electronic communications relating to client orders and the conclusion of transactions in the equity, bond, and derivatives markets. In November 2011 this was extended to cover the recording of mobile phone conversations that related to client orders and transactions by regulated firms. The situation in Scotland is similar to that in England and Wales, cover by the Regulation of Investigatory Powers (Scotland) Act 2000. In "Rathbun v United States", the U.S. Supreme Court ruled in regard to interstate or foreign communication that "the clear inference is that one entitled to receive the communication may use it for his own benefit or have another use it for him. The communication itself is not privileged, and one party may not force the other to secrecy merely by using a telephone. It has been conceded by those who believe the conduct here violates Section 605 [of the Federal Communication Act] that either party may record the conversation and publish it." See United States v. Polakoff, 113 F. 2d 888, 889. Federal law requires that at least one party taking part in the call must be notified of the recording (18 U.S.C. §2511(2)(d)). Call recording laws in some U.S. states require only one party to be aware of the recording, while other states generally require both parties to be aware. Several states require that all parties consent when one party wants to record a telephone conversation. Telephone recordings are governed by federal law and by mainly two types of state laws:  States that generally require that all parties consent to the recording include:   One-party consent states are:  Some states distinguish between electronic and in-person communication. For example, Oregon is a one-party consent state for electronic communication, but requires all-party consent for live in-person communication, with a few exceptions. The California Supreme Court ruled in 2006 that if a caller in a one-party state records a conversation with someone in California, that one-party state caller is subject to the stricter of the laws and must have consent from all callers (cf. "Kearney v. Salomon Smith Barney Inc.", 39 Cal. 4th 95). However, non-disclosure recordings by one of the parties can legally be made if the other party is threatening kidnapping, extortion, bribery, human trafficking, or other felony violence.