Regulatory Alerts2013-04-08 | 2013-07538Swap Dealers and Major Swap Participants; Clerical or Ministerial Employees
The Commodity Futures Trading Commission proposes to amend Regulation 23.22 to clarify that the prohibition against statutorily disqualified persons does not apply to employees performing solely clerical or ministerial duties. This change aligns the regulation with the Commodity Exchange Act's exclusion of such employees from the definition of an associated person of a swap dealer or major swap participant. The proposal aims to reduce compliance costs by confirming that swap dealers and major swap participants are not required to assess the disqualification status of these specific employees.
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