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Email The Commodity Futures Trading Commission issued a release that would make significant revisions to the regulatory requirements that apply under Part 37 of the CFTC Rules to the trading of swaps and to the market places that offer “exchange trading” of swaps. Beyond amending the Existing Rules, the SEF Proposing Release would substantially reinterpret two statutory terms: (i) the definition of a “swap execution facility” in CEA Section 1a(50) and (ii) the meaning of the phrase “makes the swap available to trade” in Section 2(h)(8) of the Commodity Exchange Act. https://www.cadwalader.com/resources/clients-friends-memos/swap-execution-facilities-the-sequel-