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The United States and Switzerland signed the attached Memorandum of Understanding setting forth certain clarifications of terms used in the Model 2 IGA Agreement, previously entered into by the two countries on February 14, 2013. The primary provision describes the scope of the FFI Agreement to which each Swiss Financial Institution is required to agree. See: Memo.

This OCC Bulletin reminds the management of national banks, federal savings associations, and federal branches and agencies of foreign banks (collectively, banks) to be aware of the CFTC swap clearing rules, which will come into effect for banks that are not swap dealers on June 10, 2013, as to those swaps that are subject to a mandatory clearing requirement. See: Press Release.

The CFTC Division of Clearing and Risk issued an Advisory notifying market participants that the effective date of the final rule adopting the “Clearing Exemption for Swaps Between Certain Affiliated Entities” has been automatically extended by operation of law until June 18, 2013 (as opposed to June 10, which had been the date set forth in the release). The Advisory likewise states that the clearing requirement under Section 2(h)(1)(A) of the Commodity Exchange Act and CFTC Rule Part 50 does not apply until that date. Lofchie Comment: The upshot of the Advisory is presumably that the