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If the foreign account is deemed a foreign affiliate of an existing CFTC-registered FDM, then using the 360-day extension seems inappropriate to me for financial institutions.
FORBES: Questions Linger Regarding New Forex Rules
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Because smaller companies cannot spare the time or money needed to set up a sham foreign affiliate, big companies receive a disproportionate advantage in reaching global markets.
ECONOMIST: Economics focus
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Hollande landed in Sevare accompanied by his defense and foreign ministers, CNN affiliate BFMTV reported.
CNN: STORY HIGHLIGHTS
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He is a member of the Pacific Council on International Policy, the West Coast Affiliate of the Council on Foreign Relations.
WHITEHOUSE: The White House