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Legal Update

The New CFTC and SEC Swap “Entity” Definitions—Highlights

30 April 2012
Mayer Brown Legal Update
Last Friday, the US Commodity Futures Trading Commission and Securities and Exchange Commission (the “Commissions”) released the text of their final rulemaking further defining the terms “swap dealer,” “security-based swap dealer,” “major swap participant,” “major security-based swap participant” and “eligible contract participant.” In the report linked to below, we offer selected observations on the final rules and the Commissions’ interpretive guidance.


  • Curtis A. Doty
    T +1 212 506 2224
  • Jerome J. Roche
    T +1 202 263 3773
  • David R. Sahr
    T +1 202 263 3332
  • Donald S. Waack
    T +1 202 263 3165
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