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CFTC Dodd-Frank Rulemaking The CFTC is proposing rules that would implement regulations whereby swaps in agricultural commodities and all commodity options (including options on both agricultural and non-agricultural commodities), other than options on futures, may transact subject to the same rules as all other swaps. The proposed rules for swaps in an agricultural commodity would repeal and replace the CFTC's regulations concerning the exemption of swap agreements. Document Number 76 Fed. Reg. 6095 Date February 3, 2011 Closing Date for Comments: April 4, 2011 Cross References Dodd-Frank Act

FIA ISDA RIN 3038-AD21 April 1, 2011 FIA and ISDA File Comment Letter on Commodity Options and Agricultural Swaps (April 1, 2011) FIA and ISDA filed a joint letter on April 1 commenting on the CFTC's proposed rule on the regulation of commodity options and agricultural swaps that are traded over-the-counter. The two associations expressed support for the proposal to apply the same rules to agricultural swaps that apply to all other OTC commodity derivatives under the Dodd-Frank Act, rather than applying separate or more restrictive rules to these products, and to treat agricultural trade

Open Meeting CFTC Press Release 6148-11 The CFTC held a public meeting on, December 5, 2011 on the following topics: (1) Final Rule on Investment of Customer Funds and Funds Held in an Account for Foreign Futures and Options Transactions; (2) Further Notice of Proposed Rulemaking on Process for Making a Swap Available to Trade under Section 2(h)(8) of the Commodity Exchange Act (3) Final Rule on Registration of Foreign Boards of Trade The CFTC unanimously approved items (1) and (3), and item (2) by a vote of 4-1. Highlights of the CFTC's actions include: Rule 1.25 Changes The changes in Rule 1

76 FR XXXX The CFTC has adopted a final rule regarding the investment of customer funds by FCMs and DCOs that i) eliminates in-house transactions and repurchase agreements with affiliates (repos with third-parties are still allowed, subject to a 25% counterparty concentration limit); ii) eliminates foreign sovereign debt as a permitted investment; iii) limits investments in money market mutual funds based on a number of factors, and iv) and harmonizes Rule 30.7 with the investment limitations of Rule 1.25 and the concentration limits on various investments to promote portfolio diversification

76 FR 78766 The CFTC has adopted a final rule regarding the investment of customer funds by FCMs and DCOs that i) eliminates in-house transactions and repurchase agreements with affiliates (repos with third-parties are still allowed, subject to a 25% counterparty concentration limit); ii) eliminates foreign sovereign debt as a permitted investment; iii) limits investments in money market mutual funds based on a number of factors, and iv) and harmonizes Rule 30.7 with the investment limitations of Rule 1.25 and the concentration limits on various investments to promote portfolio diversification