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On Friday, May 18, 2012, the Commodity Futures Trading Commission (the "CFTC") approved a final rule on swap data recordkeeping and reporting requirements for counterparties to swaps executed prior to passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") and those entered into between the law’s enactment date and the applicable compliance date for swap data recordkeeping and reporting.

On Tuesday, October 11, 2011, the Office of the Comptroller of the Currency (the "OCC"), the Federal Reserve Board (the "Fed"), the Federal Deposit Insurance Corporation (the "FDIC"), and the Securities and Exchange Commission (the "SEC") jointly issued proposed regulation implementing the so-called "Volcker Rule" requirements of section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").