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The CFTC, the SEC and prudential regulators in the United States have made significant progress on the detailed rules to implement the swap market reforms contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act. The principal changes are in the process of coming into effect, and market practitioners need to understand the scope of the work ahead of them.

Working with the Investment Management Association, Clifford Chance has prepared a first update of its summary of key provisions of the draft rules as they apply to UK and other non-US asset managers and their clients. Many of the provisions described in the summary apply equally to other market participants.

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