The CFTC recently proposed rules under the Dodd-Frank Act that create significant uncertainty for employee benefit plans subject to ERISA, and other "Special Entities" (as defined in Dodd-Frank and explained further in the link below) entering into swap transactions. Employee benefit plans subject to ERISA (and investment vehicles into which such plans invest) regularly engage in swap transactions to hedge against market risks. Swaps also help defined benefit pension plan sponsors reduce volatility and make funding obligations more predictable. Click here to read more.