Searching For Swap Regulation Relief Under Dodd-Frank

Law360, New York (September 20, 2012, 12:20 PM ET) -- As a general matter, commodity swaps and options on commodities, whether or not physically settled, are subject to regulation under the Dodd-Frank Wall Street Reform and Consumer Protection Act.

This is because the definition of "swap" contained in the Commodities Exchange Act (CEA) includes any agreement commonly known as an energy swap, an emissions swap or a commodity swap and any option on any such agreement. In addition, the term "swap" includes an "option of any kind that is for the purchase or sale, based on...
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