In the military they call it “mission creep”, when a campaign expands well beyond its original objectives. Goals begin to shift, and the resulting mission may look nothing like what was originally intended. To say that Thanksgiving shopping is experiencing mission creep is an understatement. Retailers, seeking a leg up on the competition, began to experiment with an earlier start to the holiday shopping season, and midnight of Thanksgiving became the new battle line. Ever emboldened to make the most of Black Friday, retailers like Wal-Mart, Sears and Target then shifted the line towards 8PM, figuring most turkeys had been cooked and consumed by then, and shoppers were surely ready for some spending action. Now, the front line has shifted yet again, as Retailer Kmart announced a 6AM opening on Thanksgiving. Black Friday, as it were, is now Thanksgiving, the…

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Impact on Mortgage REITs and Structured Finance Companies Impact on Mortgage REITs and Structured Finance Companies Guide

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Overview of Central Clearing Requirements for End-User Exception: 1. Must not be a financial entity (small bank exemption can be used for banks with less than $10bn in assets) 2. Must be hedging commercial risk 3. If public, must have board approval to not clear trades 4. Must complete CFTC end-user exception questionnaire and submit to a swap data repository Clearing Timeline 1. Proposed mandatory clearing determination published by CFTC in the Federal Register on August 7th, 2012. 2. 30 day comment period ends September 6th, 2012. 3. Final mandatory clearing determination released as early as September 7th, 2012 (not expected to slip more than a month or two if it does slip) 4. Swap dealers, major swap participants, and active funds (private funds executing an average of 20 trades or more a month) required to clear as early as…

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