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Email The Administration has published a significant piece of proposed legislation, the “Over the Counter Derivatives Markets Act of 2009” (the “Legislation”) that would govern the swaps market, both the transactions and participants. The Legislation reaches far beyond the swaps markets, having application to spot or cash market trading, and potentially to entities such as operating companies that would not ordinarily be regarded as swap market participants. https://www.cadwalader.com/resources/clients-friends-memos/over-the-counter-derivatives-markets-act-of-2009