Treatment of Commercial End-Users of Swaps

PLI Webinar

04/07/2015 01:00 p.m. - 02:00 p.m. EDT

Banking + Financial Services, Corporate Finance | Capital Markets, Derivatives + Commodities, Financial Institutions + Financial Services, and Derivatives + Commodities Regulation

James Schwartz and Julian E. Hammar

Julian E. Hammar and James Schwartz


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Harrison Lawrence
(212) 336-4004

Join Morrison & Foerster for this one-hour briefing which will review the status and responsibilities of commercial end users of swaps under Title VII of Dodd-Frank and the regulations thereunder.  In analyzing the impact of Title VII on commercial end users, we will review the ways in which the regulators have distinguished between commercial end-users and other types of swap market participants, including with respect to clearing, swap execution, margin, reporting and recordkeeping requirements.  This session will discuss:

  • Treatment of commercial end users under the CFTC’s and Prudential Regulators’ Uncleared Swaps Margin Proposals;
  • The requirements for end-users seeking to take advantage of the exemption from the clearing requirement;
  • The CFTC’s forward with embedded volumetric optionality proposed interpretation; and
  • Exclusion of utility operations swaps from the special entity de minimis calculation for swap dealer status. 


  • Julian E. Hammar
    Morrison & Foerster LLP
  • James Schwartz
    Morrison & Foerster LLP

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