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Commentary by Nihal Patel

The SEC proposed three new rules relating to security-based swaps: (1) an anti-fraud rule, (2) a rule to require reporting of large positions in security-based swaps, and (3) a rule prohibiting personnel of an SBS entity from taking any action to improperly interfere with the SBS entity's CCO in the performance of such persons duties.

Commentary by Nihal Patel

FINRA proposed delaying the expiry date of Rule 0180 on the application of FINRA rules to security-based swaps, and extending the implementation date of Rule 4240 on margin requirements for credit default swaps.