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The Dodd-Frank Act requires “swap dealers” to register with the Commodity Futures Trading Commission (CFTC) and to comply with a number of detailed and onerous regulations. The swap dealer registration regime is at the heart of the derivatives reforms brought about under Dodd-Frank. While every party entering into “swaps” transactions will have certain obligations under the CFTC’s new regulatory regime, swap dealers bear the heaviest compliance burden.

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