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External Meetings: Teleconference with Sutherland
XXI. Joint Rules w/ SEC
Stephen Roth (Sutherland)
Fredrick Bellamy (Sutherland)
Participants discussed the proposed product definitions rulemaking, and in particular focused on the exclusion for insurance from the swap definition contained in the proposed rule text and interpretive guidance. Issues discussed included the structure of the proposed exclusion as rule text and guidance, and the scope of the guidance excluding life insurance and annuities from the swap and security-based swap definitions.