On September 10, 2012, the CFTC published a FAQ addressing questions related to determining when an entity is requiredto register as a swap dealer. The CFTC addressed the following:

The swap dealer registration regulations go into effect on October 12, 2012 and entities that have more than the deminimis level of dealing must register by no later than two months after the end of the month in which they surpass the de minimis level. Swap dealing will be counted from October 12, 2012 meaning that a person whose swap dealingsexceed an applicable gross notional amount threshold on October 13, 2012 will be a “swap dealer” as of October 13,2012 but has until December 31, 2012 to register (i.e., two months after the end of the month in which the person’sswaps exceeded either of the thresholds).

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