INTRODUCTION AND OVERVIEW OF DODD-FRANK TITLE VII -

Title VII of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act ("Title VII" or "Dodd- Frank"), enacted on July 21, 2010, provided for the first time a comprehensive regulatory framework for the over-the-counter ("OTC") derivatives markets. Fundamentally, Title VII aimed to prevent future financial crises by mandating robust market and transaction level transparency while reducing structural leverage and systemic risk throughout the derivatives markets.

Title VII codified the global de-risking process underway since the 2008-2009 financial crisis with particular focus on:

- reducing counterparty risk and enhancing transparency and price discovery by requiring clearing and exchange trading of eligible derivatives contracts;

- deleveraging the OTC derivatives markets by imposing new regulatory capital and margin requirements on OTC swap dealers (?SDs?) and security-based swap dealers (?SBSDs?) and on certain OTC major swap participants (?MSPs?) and major security-based swap participants (?MSBSPs?);

- requiring SDs, SBSDs, MSPs, and MSBSPs to register with the U.S. Securities and Exchange Commission (?SEC?) and/or the U.S. Commodity Futures Trading Commission (?CFTC?) and to continuously disclose detailed information regarding their derivatives trading activities; and

- prohibiting U.S. Federal guarantees and other Federal assistance from being provided to insured depository institutions involved in the swap markets, subject to exceptions for affiliated SDs and certain swap activities related to bona fide hedging and traditional bank activities.

Certain portions of Title VII remain subject to further rulemaking by the SEC and the CFTC. This outline reviews various developments under Dodd-Frank relating to swaps and other derivatives applicable to U.S. mutual funds, as well as other funds and market participants, that trade in swaps. This outline is current as of its publication date specified on the cover page, and it has not been updated or supplemented since then.