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On January 11, 2012, the U.S. Commodity Futures Trading Commission (the "CFTC") approved final rules (the "Final Rules") establishing a registration process for swap dealers ("SDs") and major swap participants ("MSPs" and, together with SDs, "Swap Entities"), as required under Sections 4s(a) and 4s(b) of the Commodity Exchange Act (the "CEA"), which were inserted by the Dodd-Frank Act.

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