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In the letter, the Associations urge the regulators to use their statutory discretion to exclude inter-affiliate swap transactions from margin requirements, consistent with the risk-based approach to implementation contemplated by the relevant statute.

NURFS, joined by several trade association partners, submitted a comment letter to the CFTC regarding its Exemptive Order on compliance with certain cross-border swaps provisions.

NURFS filed comment letter with CFTC explaining why its proposal is inadequate and would negatively affect U.S. and foreign swap dealers.