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Overview
This briefing will review the status and responsibilities of commercial end users of swaps under Title VII of Dodd-Frank and the regulations thereunder. In analyzing the impact of Title VII on commercial end users, we will review the ways in which the regulators have distinguished between commercial end-users and other types of swap market participants, including with respect to clearing, swap execution, margin, reporting and recordkeeping requirements.
Please join Julian E. Hammar and James Schwartz of Morrison & Foerster LLP as they discuss, among other topics:
- Treatment of commercial end users under the CFTC’s and Prudential Regulators’ Uncleared Swaps Margin Proposals
- The requirements for end-users seeking to take advantage of the exemption from the clearing requirement
- The CFTC’s forward with embedded volumetric optionality proposed interpretation
- Exclusion of utility operations swaps from the special entity de minimis calculation for swap dealer status