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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.


  • Joshua Cohn
    Senior Counsel, Independent Contractor
    T +1 212 506 2539
  • Curtis A. Doty
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  • Jerome J. Roche
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  • David R. Sahr
    T +44 20 3130 3496
  • Donald S. Waack
    T +1 202 263 3165

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