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Expert Analysis

Putting The CFTC's 'Swap' Definition Into Context

Law360, New York (June 5, 2014, 1:05 PM EDT) -- The U.S. Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight recently addressed, for the first time, the commission's definition of a swap as it applies to a specific insurance transaction.[1] On the basis of the division's guidance in Action Letter 14-67 ("NAL14-67"),[2] U.S. life insurers will be able, via a Bermuda cell insurer intermediary in a properly structured transaction, to provide a reinsurance hedge to banks active in protecting non-U.S. pensions against the mortality improvements of specified individual beneficiaries....

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