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More Clarity on the End-User Clearing Exemption: FAS 133 (ASC 815) Ratified, Small Banks in Limbo

The big fear of just relying on FAS 133 was for all of the end-users who would not get the clearing exemption because either they could not be bothered to comply with FAS 133 or because their hedging programs did not work well under FAS 133, like many commodity hedges. The CFTC’s approach does allow the flexibility to leverage FAS 133 documentation where a company can and use other approaches where a company cannot.

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