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Email On October 11, 2018, the Securities and Exchange Commission (“SEC”) signaled that it is getting back into the Title VII game, by voting to re-open the comment period and request additional comment on rulemakings to adopt margin, capital, and collateral segregation requirements applicable to security-based swap dealers (“SBSDs”). The re-opening of the comment period is the first step that the SEC has taken towards implementing the statutory regime for SBSDs in over two years and also the first step under Chairman Jay Clayton. https://www.cadwalader.com/resources/clients-friends-memos/definitely-maybe-the-sec-returns-to-security-based-swap-dealer-regulation