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Email The Securities and Exchange Commission ("SEC") has adopted rules under the Securities Exchange Act (the "SEA") establishing (i) capital and margin requirements applicable to broker-dealers entering into security-based swaps ("SBS") and to security-based swap dealers ("SBSDs") that are not banks and (ii) a collateral segregation regime for SBS customers transacting with broker-dealers and with SBSDs. The Rules were first proposed in October 2012, and the comment period was reopened in a substantial release in October 2018. https://www.cadwalader.com/resources/clients-friends-memos/the-sec-adopts-security-based-swap-regulations-governing-capital-margin-and-collateral-segregation