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Final 'Business Conduct Rules' for Swap Dealers Include Safe Harbor for ERISA Plans
Deloitte via BenefitsLink 
[Guidance Overview] Jan. 31, 2012
The Commodity Futures Trading Commission (CFTC) included a safe-harbor for ERISA plans under the 'business conduct standards' for swap dealers under the Dodd-Frank Act .... In a letter to the CFTC, [DOL] affirmed that the final rule will not require swap dealers to engage in conduct that will cause them to become ERISA fiduciaries.
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