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American Benefits Council Comment Letter to CFTC/SEC on Study of Stable Value Contracts under Dodd-Frank (PDF)
Nationwide Financial Services, Inc.
[Opinion] Nov. 1, 2012 6 pages. "[The Council writes] to reemphasize the continued importance stable value contracts have with respect to our country's retirement security and reiterate that these contracts are not swaps.... [T]his is the best approach because the use of exemptive authority to relieve stable value contracts of the burdens of swap regulation, while a reasonable second-best solution, could have unintended consequences.... The Commissions' final regulations defining swaps reiterate Congress' intent to exclude insurance products from the definition of swap.... The same analysis is applicable to all stable value contracts." MORE >> |
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