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In this paper, Jenner & Block Partner Timothy A. Karpoff and Associate Professor John Crawford of University of California, Hastings College of Law analyze the Swaps Pushout Rule, enacted as part of the Dodd-Frank Act. The authors explain the practical impact of the Rule and its rollback. They argue that the appropriate focus should be on capital requirements rather than the legal entity in which the swaps are booked. Bloomberg View columnist Matt Levine quotes from the paper at length in his September 1, 2015, “Money Stuff” column.