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Proposed CFTC Regulations Under Dodd-Frank Could Jeopardize Swaps with ERISA Plans
Orrick, Herrington & Sutcliffe LLP 
[Guidance Overview] Jan. 20, 2011
The Proposed Regulations resurrect the issue ... that swap dealers engaging in typical business activities with respect to Special Entities could be treated as an ERISA fiduciaries.
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