Effective Date of Swaps Pushout Provision

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On March 30, the FDIC, Fed, and OCC issued guidance clarifying that the effective date of Section 716 of the Dodd-Frank Act (known as the Swaps Pushout provision) is July 16, 2013. Section 716 prohibits the provision of Federal assistance to any entity defined under that section to be a swaps entity with respect to any swap, security-based swap, or other activity of the swaps entity.  Joint Release.  Guidance.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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