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22 Results
November 01, 2018
Commentary by Nihal Patel

The SEC issued a "Commission Statement" to provide relief from aspects of the security-based swap dealer ("SBSD") business conduct rules, primarily the treatment of special entities. The SEC stated that the action is in response to "practical compliance difficulties" raised by market participants. The relief allows market participants to rely on representations in the context of complying with CFTC external business conduct requirements. In particular, the statement takes the following "no-action" positions that are "limited to the Commission's enforcement discretion . . . and does not modify