On August 16th, the CFTC published for comment a proposed rule exempting swaps between certain affiliated entities within a corporate group from the clearing requirement of the Dodd-Frank Act. The posting of variation margin would still be required. The proposal is the result of the CFTC's consideration of whether alternative methods of counterparty risk mitigation may be appropriate for swaps between majority-owned affiliates of the same corporate group. Comments should be submitted within 30 days after publication in the Federal Register, which is expected during the week of August 20. CFTC Press Release; CFTC Questions and Answers.