Dodd-Frank requires that most swaps be cleared through a regulated clearinghouse if the clearinghouse accepts the swap for clearing. Under the proposed rules, all non-exempt swaps (., swaps that are not subject to the “End User” exception discussed below) are generally expected to be subject to clearing and exchange trading requirements. 23 Additionally, swaps approved for clearing must be traded on a registered exchange approved by the applicable regulator (., the CFTC or the SEC, depend- ing on the type of swap), unless no registered exchange accepts the swap for trading. 24 Dodd-Frank creates an exception from mandatory clearing and exchange trading for “End-Users.”25.
