the Act are the rules regulating the overthe-counter (OTC) market. Commonly referred to as “derivative reform,” these rules are far-reaching and complex. As written, derivative reform addresses all types of swaps: equity, interest rate, foreign exchange, credit default and commodity. For energy companies trading OTC commodity swaps there are four major areas to evaluate for business impact: clearing, data and reporting, position limits and new business conduct rules. Since no current…
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