Comparability Determination for Japan: Certain Transaction-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 request by the Bank of Tokyo-Mitsubishi UFJ, Ltd ("BTMU") that the Commission determine that laws and regulations applicable in the Japan 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) Swap trading relationship documentation and (ii) daily trading records (collectively, the "Business Conduct Requirements").