Comparability Determination for the European Union: Certain Entity-Level Requirements

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The following is the analysis and determination of the Commodity Futures Trading Commission ("Commission") regarding certain parts of a joint request by the European Commission ("EC") and the European Securities and Markets Authority ("ESMA") that the Commission determine that laws and regulations applicable in the European Union ("EU") provide a sufficient basis for an affirmative finding of comparability with respect to the following regulatory obligations applicable to swap dealers ("SDs") and major swap participants ("MSPs") registered with the Commission: (i) Chief compliance officer; (ii) risk management; and (iii) swap data recordkeeping; (collectively, the "Internal Business Conduct Requirements").