On the eve of a critical December 31, 2012 deadline for many market participants in the global over-the-counter ("OTC") derivatives market, the US Commodity Futures Trading Commission ("CFTC") approved interim final rules (the "Rules") for the largest participants in the OTC derivatives market, Swap Dealers and Major Swap Participants, thereby affecting others in the international OTC derivatives market so long as they face Swap Dealers, Major Swap Participants and in some cases their affiliates