1
          SECURITIES AND EXCHANGE COMMISSION
          17 CFR Part 240
          [Release No. 34-41453, International Series Release No. 1198,
          File No. S7-4-99]
          RIN 3235-AH68
          Exemption of the Securities of the Kingdom of Sweden under the
          Securities Exchange Act of 1934 for Purposes of Trading Futures
          Contracts on Those Securities
          AGENCY:   Securities and Exchange Commission.
          ACTION:   Final rule.
          SUMMARY:  The Securities and Exchange Commission is adopting an
          amendment to Rule 3a12-8 that would designate debt obligations
          issued by the Kingdom of Sweden as "exempted securities" for the
          purpose of marketing and trading futures contracts on those
          securities in the United States.  The amendment is intended to
          permit futures trading on the sovereign debt of Sweden.
          EFFECTIVE DATE:  [Insert date of publication in Federal Register]
          FOR FURTHER INFORMATION CONTACT:  Joshua Kans, Attorney, Office
          of Market Supervision ("OMS"), Division of Market Regulation
          ("Division"), Securities and Exchange Commission, 450 Fifth
          Street, N.W., Washington, D.C. 20549-1001, at 202/942-0079.
          SUPPLEMENTARY INFORMATION:
          I.   Introduction
               Under the Commodity Exchange Act ("CEA"), it is unlawful to
          trade a futures contract on any individual security unless the
          security in question is an exempted security (other than a
          municipal security) under the Securities Act of 1933 ("Securities
          Act") or the Securities Exchange Act of 1934 ("Exchange Act").
          Debt obligations of foreign governments are not exempted
          securities under either of these statutes.  The Securities and
          Exchange Commission ("SEC" or "Commission"), however, has adopted
          Rule 3a12-8[1] ("Rule") under the Exchange Act to designate debt
          obligations issued by certain foreign governments as exempted
          securities under the Exchange Act solely for the purpose of
          marketing and trading futures contracts on those securities in
          the United States.  As amended, the foreign governments currently
          designated in the Rule are Great Britain, Canada, Japan,
          Australia, France, New Zealand, Austria, Denmark, Finland, the
          Netherlands, Switzerland, Germany, the Republic of Ireland,
          Italy, Spain, Mexico, Brazil, Argentina, Venezuela and Belgium
          (the "Designated Foreign Governments").  As a result, futures
          contracts on the debt obligations of these countries may be sold
          in the United States, as long as the other terms of the Rule are
          satisfied.
               On February 23, 1999, the Commission issued a release
          proposing to amend Rule 3a12-8 to designate the debt obligations
          of the Kingdom of Sweden ("Sweden") as exempted securities,
          solely for the purpose of futures trading.[2]  No comment letters
          were received in response to the proposal.
               The Commission today is adopting this amendment to the Rule,
          adding Sweden to the list of countries whose debt obligations are
          exempted by Rule 3a12-8.  In order to qualify for the exemption,
          futures contracts on the debt obligations of Sweden would have to
          meet all the other existing requirements of the Rule.
          II.  Background
               Rule 3a12-8 was adopted in 1984[3] pursuant to the exemptive
          authority in Section 3(a)(12) of the Exchange Act in order to
          provide a limited exception from the CEA's prohibition on futures
          overlying individual securities.[4]  As originally adopted, the
          Rule provided that the debt obligations of Great Britain and
          Canada would be deemed to be exempted securities, solely for the
          purpose of permitting the offer, sale, and confirmation of
          "qualifying foreign futures contracts" on such securities.  The
          securities in question were not eligible for the exemption if
          they were registered under the Securities Act or were the subject
          of any American depositary receipt so registered.  A futures
          contract on the covered debt obligation under the Rule is deemed
          to be a "qualifying foreign futures contract" if the contract is
          deliverable outside the United States and is traded on a board of
          trade.[5]
               The conditions imposed by the Rule were intended to
          facilitate the trading of futures contracts on foreign government
          securities in the United States while requiring offerings of
          foreign government securities to comply with the federal
          securities laws.  Accordingly, the conditions set forth in the
          Rule were designed to ensure that, absent registration, a
          domestic market in unregistered foreign government securities
          would not develop, and that markets for futures on these
          instruments would not be used to avoid the securities law
          registration requirements.  In particular, the Rule was intended
          to ensure that futures on exempted sovereign debt did not operate
          as a surrogate means of trading the unregistered debt.
               Subsequently, the Commission amended the Rule to include the
          debt securities issued by Japan, Australia, France, New Zealand,
          Austria, Denmark, Finland, the Netherlands, Switzerland, Germany,
          Ireland, Italy, Spain, Mexico, Brazil, Argentina, Venezuela and,
          most recently, Belgium.[6]
               OM Stockholm AB of Sweden ("OM"), and its British affiliate
          OMLX, The London Securities and Derivatives Exchange Limited
          ("OMLX"), have proposed that the Commission amend 3a12-8 to
          include the sovereign debt of Sweden.  OM and OMLX (which will be
          collectively referred to as "OM") have stated that they are
          listing standardized futures contracts on Swedish government
          securities for trading on their respective markets, beginning
          with a futures contract on the ten-year Swedish government bond.
          The applicants wish to make those futures contracts available to
          U.S. investors.[7]
               The Swedish National Debt Office submitted a letter
          supporting OM's application to amend the Rule.[8]  In 1988, the
          Commission proposed adding Sweden to the list of countries
          designated under the Rule,[9] but rejected the proposal because
          of opposition from the Swedish government.[10]
               The Commission is amending Rule 3a12-8 to add Sweden to the
          list of countries whose debt obligations are deemed to be
          "exempted securities" under the terms of the Rule.  Under this
          amendment, the existing conditions set forth in the Rule (i.e.,
          that the underlying securities not be registered in the United
          States, that futures contracts require delivery outside the
          United States, and that contracts be traded on a board of trade)
          would continue to apply.
          III. Discussion
               For the reasons discussed below, the Commission finds that
          it is consistent with the public interest and the protection of
          investors that Rule 3a12-8 be amended to include the sovereign
          debt obligations of Sweden.  The Commission believes that the
          trading of futures contracts on the sovereign debt of Sweden
          could provide U.S. investors and dealers with a vehicle for
          hedging the risks involved in holding debt instruments of Sweden,
          and that the sovereign debt of Sweden should be subject to the
          same regulatory treatment under the Rule as that of the
          Designated Foreign Governments.
               When amending the Rule to include Belgium, the Commission
          stated that it would consider two types of evidence about whether
          there was an active and liquid secondary trading market for the
          security -- credit rating (as indirect evidence) and trading
          data.[11]  Earlier, when amending the Rule to include Mexico,
          Brazil, Argentina, and Venezuela, the Commission considered
          primarily whether market evidence indicated that an active and
          liquid secondary trading market exists for the sovereign debt of
          those countries.[12]  Prior to the addition of those countries to
          the Rule, the Commission considered principally whether the
          particular sovereign debt had been rated in one of the two
          highest rating categories[13] by at least two nationally
          recognized statistical rating organizations ("NRSROs").[14]
               Sweden meets the credit rating standard.  Moody's has
          assigned Sweden a long-term local currency credit rating of Aa1
          and a long-term foreign currency credit rating of Aa2.  S&P has
          assigned Sweden a long-term local currency credit rating of AAA
          and a long-term foreign currency credit rating of AA+.
               Market data also indicates that there exists an active and
          liquid trading market for Swedish issued debt instruments.  As of
          February 28, 1999, the total Swedish public debt outstanding was
          equivalent to approximately US$173 billion (1428 billion Swedish
          kronor ("SEK")).[15]  The largest portion of this debt, Treasury
          bonds (Statsobligationsln) denominated in Swedish kronor,
          amounted to approximately US$94 billion (SEK 773 billion).[16]
          Treasury bills (Statsskuldvxlar) denominated in Swedish kronor
          amounted to approximately US$27 billion (SEK 227 billion).[17]
               OM has submitted data indicating that secondary market
          trading in Treasury bonds amounted to approximately US$1.2
          trillion (SEK 9079 billion) in 1996, approximately US$1.3
          trillion (SEK 10,550 billion) in 1997, and approximately US$1.2
          trillion (SEK 9098 billion) in 1998.[18]  The average daily
          trading volume during that period ranged from approximately
          US$2.1 billion (SEK 16.6 billion) for the month of July 1998 to
          approximately US$8.3 billion (SEK 65.6 billion) for the month of
          October 1997.  OM adds that there were approximately 109,100
          transactions in benchmark Treasury bonds in 1997 and 274,000 in
          1998; 27,500 transactions in non-benchmark Treasury bonds in 1997
          and 7900 in 1998; and 2000 transactions in inflation-linked
          Treasury bonds in 1997 and 10,800 in 1998.[19]
               OM has also submitted data stating that secondary market
          trading in Treasury bills amounted to approximately US$440
          billion (SEK 3452 billion) in 1996, approximately US$488 billion
          (SEK 3831 billion) in 1997, and approximately US$447 billion (SEK
          3511 billion) in 1998.  The average daily trading volume during
          that period ranged from approximately US$1.2 billion (SEK 9.3
          billion) for the month of May 1996 to approximately US$2.6
          billion (SEK 20.7 billion) for the month of March 1997.  OM adds
          that there were approximately 38,600 transactions in Treasury
          bills in 1997 and 76,800 in 1998.[20]
               The Commission finds that this trading data, coupled with a
          high debt rating, provides sufficient evidence that there exists
          an active and liquid market for Swedish sovereign debt.
          IV.  Costs and Benefits of the Proposed Amendments
               The Commission believes that the amendment offers potential
          benefits for U.S. investors.  As stated above, the amendment will
          allow U.S. and foreign boards of trade to offer in the United
          States, and U.S. investors to trade, futures contracts on the
          debt obligations of Sweden.  Consistent with Congressional
          support for futures on foreign sovereign debt securities, the
          trading of futures on the sovereign debt of Sweden should provide
          U.S. investors with a vehicle for hedging the risks involved in
          the trading of the underlying sovereign debt of Sweden.  The
          amendment does not impose any direct recordkeeping or compliance
          costs, and merely would provide a limited purpose exemption under
          the federal securities laws.  The restrictions imposed under the
          amendment are identical to the restrictions currently imposed
          under the terms of the Rule and are designed to protect U.S.
          investors.
          V.   Effects of the Proposed Amendment on Competition, Efficiency
               and Capital Formation, and Other Findings
               Section 23(a)(2) of the Exchange Act[21] requires the
          Commission, in adopting rules under the Exchange Act, to consider
          the competitive effects of such rules, if any, and to refrain
          from adopting a rule that would impose a burden on competition
          not necessary or appropriate in furthering the purposes of the
          Exchange Act.  Moreover, Section 3 of the Exchange Act[22] as
          amended by the National Securities Markets Improvement Act of
          1996[23] provides that whenever the Commission is engaged in a
          rulemaking and is required to consider or determine whether an
          action is necessary or appropriate in the public interest, the
          Commission shall consider, in addition to the protection of
          investors, whether the action will promote efficiency,
          competition and capital formation.
               The Commission has considered the amendment to the Rule in
          light of the standards cited in Sections 3 and 23(a)(2), and the
          Commission believes that adoption of the amendment will not
          impose any burden on competition not necessary or appropriate in
          furtherance of the purposes of the Exchange Act.  As stated
          above, the amendment is designed to assure the lawful
          availability in this country of futures contracts on the
          government debt of Sweden that otherwise would not be permitted
          to be marketed under the terms of the CEA.  The amendment thus
          serves to expand the range of financial products available in the
          United States and enhances competition in financial markets.  The
          Commission has considered the amendment's impact on efficiency,
          competition, and capital formation and concludes that it would
          promote these three objectives, by making available to U.S.
          investors an additional product to use to hedge the risks
          associated with the trading of the underlying sovereign debt of
          Sweden.[24]  Insofar as the Rule contains limitations, they are
          designed to promote the purposes of the Exchange Act by ensuring
          that futures trading on government securities of Sweden is
          consistent with the goals and purposes of the federal securities
          laws by minimizing the impact of the Rule on securities trading
          and distribution in the United States.
               Because the amendment to the Rule is exemptive in nature,
          the Commission has determined to make the foregoing action
          effective immediately upon publication in the Federal
          Register.[25]
          VI.  Administrative Requirements
               Pursuant to Section 605(b) of the Regulatory Flexibility
          Act, 5 U.S.C. 605(h), the Chairman of the Commission has
          certified in connection with the Proposing Release that this
          amendment, if adopted, would not have a significant economic
          impact on a substantial number of small entities.  The Commission
          received no comments on this certification.
               The Paperwork Reduction Act does not apply because the
          amendment does not impose recordkeeping or information collection
          requirements, or other collections of information which require
          the approval of the Office of Management and Budget under 44
          U.S.C. 3501, et seq.
          VII. Statutory Basis
               The amendment to Rule 3a12-8 is being adopted pursuant to 15
          U.S.C. 78a et seq., particularly Sections 3(a)(12) and 23(a), 15
          U.S.C. 78c(a)(12) and 78w(a).
          List of Subjects in 17 CFR Part 240
               Reporting and recordkeeping requirements, Securities.
          Text of the Amendment
               For the reasons set forth in the preamble, the Commission
          amends Part 240 of Chapter II, Title 17 of the Code of Federal
          Regulations as follows:
          PART 240 - GENERAL RULES AND REGULATIONS, SECURITIES EXCHANGE ACT
          OF 1934
               1.  The authority citation for Part 240 continues to read in
          part as follows:
               Authority: 15 U.S.C. 77c, 77d, 77g, 77j, 77s, 77z-2, 77eee,
          77ggg, 77nnn, 77sss, 77ttt, 78c, 78d, 78f, 78i, 78j, 78j-1, 78k,
          78k-1, 78l, 78m, 78n, 78o, 78p, 78q, 78s, 78u-5, 78w, 78x,
          78ll(d), 78mm, 79q, 79t, 80a-20, 80a-23, 80a-29, 80a-37, 80b-3,
          80b-4 and 80b-11, unless otherwise noted.
                         *         *         *         *         *
               2.  Section 240.3a12-8 is amended by removing the word "or"
          at the end of paragraph (a)(1)(xviii), removing the period at the
          end of paragraph (a)(1)(xix) and adding "; or" in its place, and
          adding paragraph (a)(1)(xx), to read as follows:
           240.3a12-8 Exemption for designated foreign government
                    securities for purposes of futures trading.
               (a)  * * *
               (1)  * * *
               (xxi) The Kingdom of Sweden.
                         *         *         *         *         *
          By the Commission.
                                             Jonathan G. Katz
          Secretary
          Dated:  May 26, 1999
          **FOOTNOTES**
       [1]: 17 CFR 240.3a12-8.
       [2]: See Securities Exchange Act Release No. 41090 (February
            23, 1999), 64 FR 9948 (March 1, 1999) ("Proposing
            Release").
       [3]: See Securities Exchange Act Release No. 20708
            ("Original Adopting Release") (March 2, 1984), 49 FR
            8595 (March 8, 1984); Securities Exchange Act Release
            No. 19811 ("Original Proposing Release") (May 25,
            1983), 48 FR 24725 (June 2, 1983).
       [4]: In approving the Futures Trading Act of 1982, Congress
            expressed its understanding that neither the SEC nor
            the Commodity Futures Trading Commission ("CFTC") had
            intended to bar the sale of futures on debt obligations
            of the United Kingdom of Great Britain and Northern
            Ireland to U.S. persons, and its expectation that
            administrative action would be taken to allow the sale
            of such futures contracts in the United States. See
            Original Proposing Release, supra note 3, 48 FR at
            24725 (citing 128 Cong. Rec. H7492 (daily ed. September
            23, 1982) (statements of Representatives Daschle and
            Wirth)).
       [5]: As originally adopted, the Rule required that the board
            of trade be located in the country that issued the
            underlying securities.  This requirement was eliminated
            in 1987. See Securities Exchange Act Release No. 24209
            (March 12, 1987), 52 FR 8875 (March 20, 1987).
       [6]: As originally adopted, the Rule applied only to British
            and Canadian government securities.  See Original
            Adopting Release, supra note 3.  In 1986, the Rule was
            amended to include Japanese government securities. See
            Securities Exchange Act Release No. 23423 (July 11,
            1986), 51 FR 25996 (July 18, 1986).  In 1987, the Rule
            was amended to include debt securities issued by
            Australia, France and New Zealand.  See Securities
            Exchange Act Release No. 25072 (October 29, 1987), 52
            FR 42277 (November 4, 1987).  In 1988, the Rule was
            amended to include debt securities issued by Austria,
            Denmark, Finland, the Netherlands, Switzerland, and
            West Germany.  See Securities Exchange Act Release No.
            26217 (October 26, 1988), 53 FR 43860 (October 31,
            1988).  In 1992 the Rule was again amended to (1)
            include debt securities offered by the Republic of
            Ireland and Italy, (2) change the country designation
            of "West Germany" to the "Federal Republic of Germany,"
            and (3) replace all references to the informal names of
            the countries listed in the Rule with references to
            their official names.  See Securities Exchange Act
            Release No. 30166 (January 8, 1992), 57 FR 1375
            (January 14, 1992).  In 1994, the Rule was amended to
            include debt securities issued by Spain.  See
            Securities Exchange Act Release No. 34908 (October 27,
            1994), 59 FR 54812 (November 2, 1994).  In 1995, the
            Rule was amended to include the debt securities of
            Mexico.  See Securities Exchange Act Release No. 36530
            (November 30, 1995), 60 FR 62323 (December 6, 1995).
            In 1996, the Rule was amended to include debt
            securities issued by Brazil, Argentina, and Venezuela.
            See Securities Exchange Act Release No. 36940 (March 7,
            1996), 61 FR 10271 (March 13, 1996).  Finally, earlier
            in 1999, the Rule was amended to include debt
            securities issued by Belgium.  See Securities Exchange
            Act Release No. 41116 (February 26, 1999), 64 FR 10564
            (March 5, 1999).
       [7]: See Letters from Philip McBride Johnson, counsel for OM
            and OMLX, to Jonathan Katz, Secretary, Commission,
            dated June 11, 1998; Memorandum provided by OM and OMLX
            to the Division of Market Regulation on July 6, 1998;
            Letter from Philip Johnson to Michael Walinskas, Deputy
            Associate Director, Division, Commission, dated July
            24, 1998; Letters from Philip Johnson to Joshua Kans,
            Attorney, Division, Commission, dated August 20,
            September 11 and October 2, 1998; Letter from Philip
            Johnson to Michael Walinskas, dated December 7, 1998;
            Letters from Philip Johnson to Joshua Kans, dated March
            31 and April 19, 1999 (collectively "OM petition").
       [8]: See Letter from Tomas Magnusson, Director and General
            Counsel, Swedish National Debt Office, to Jonathan
            Katz, Secretary, Commission, dated June 29, 1998.
       [9]: See Securities Exchange Act Release No. 25998 (August
            16, 1988), 53 FR 31709 (August 19, 1988).
       [10]: The Embassy of Sweden submitted two letters in
            response to the 1988 proposal, noting that currency
            controls prohibiting non-residents from holding Swedish
            kronor-denominated securities would preclude
            development of a market for physically settled futures
            on such securities, and stating that in any case it was
            not in the Swedish government's interest that such a
            market develop.  As a matter of international comity,
            the Commission chose not to add Sweden to the Rule.
            See Securities Exchange Act Release No. 26217 (October
            26, 1988), 53 FR 43860 (October 31, 1988).
       [11]: See Securities Exchange Act Release No. 41116
            (February 26, 1999), 64 FR 10564 (March 5, 1999).
       [12]: See, e.g., Securities Exchange Act Release No. 36530
            (November 30, 1995), 60 FR 62323 (December 6, 1995)
            (amending the Rule to add Mexico because the Commission
            believed that as a whole, the market for Mexican
            sovereign debt was sufficiently liquid and deep for the
            purposes of the Rule); Securities Exchange Act Release
            No. 36940 (March 7, 1996), 61 FR 10271 (March 13, 1996)
            (amending the Rule to add Brazil, Argentina and
            Venezuela because the Commission believed that the
            market for the sovereign debt of those countries was
            sufficiently liquid and deep for the purposes of the
            Rule).
       [13]: The two highest categories used by Moody's Investor
            Services ("Moody's") for long-term debt are "Aaa" and
            "Aa."  The two highest categories used by Standard and
            Poor's ("S&P") for long-term debt are "AAA" and "AA."
       [14]: See, e.g., Securities Exchange Act Release No. 30166
            (January 6, 1992) 57 FR 1375 (January 14, 1992)
            (amending the Rule to include debt securities issued by
            Ireland and Italy -- Ireland's long-term sovereign debt
            was rated Aa3 by Moody's and AA- by S&P, and Italy's
            long-term sovereign debt was rated Aaa by Moody's and
            AA+ by S&P); and Securities Exchange Act Release No.
            34908 (October 27, 1994), 59 FR 54812 (November 2,
            1994) (amending the Rule to include Spain, which had
            long-term debt ratings of Aa2 from Moody's and AA from
            S&P); see also Securities Exchange Act Release No.
            36213 (September 11, 1995), 60 FR 48078 (September 18,
            1995) (proposal to add Mexico to list of countries
            encompassed by the Rule); Securities Exchange Act
            Release No. 24428 (May 5, 1987), 52 FR 18237 (May 14,
            1987) (proposed amendment, which was not implemented,
            that would have extended the Rule to encompass all
            countries rated in one of the two highest categories by
            at least two NRSROs).
       [15]: Data regarding the amount of outstanding debt was
            obtained from "Den Svenska Statsskulden:  The Swedish
            Central Government Debt," February 28, 1998, available
            from the website of the Swedish National Debt Office
            (http://www.sndo.se).  U.S. dollar equivalents for the
            February 28, 1999 data about outstanding debt is based
            on the conversion rate of SEK 8.2538 for US$1.00 in
            effect as of March 1, 1999.
            The last country added to the index, Belgium, had an
            outstanding public debt equal to approximately US$264
            billion at the end of 1997.  See Securities Exchange
            Act  Release No. 41116 (February 26, 1999), 64 FR
            10564 (March 5, 1999).  The four countries last
            added to the list prior  to Belgium -- Mexico,
            Brazil, Argentina and Venezuela --  had lower
            amounts of public debt.  See Securities Exchange
            Act Release No. 36530 (December 6, 1995), 60 FR 62323
            (December 6, 1995) (outstanding Mexican government debt
            amounted to approximately US$87.5 billion face value as
            of  March 31, 1995); Securities Exchange Act Release
            No. 36940 (March 7, 1996), 61 FR 10271 (March 13,
            1996) (public and publicly guaranteed debt of
            Brazil, Argentina and Venezuela  amounted to
            approximately US$86 billion, US$55 billion and
            US$74 billion, respectively, as of December 31, 1993).
       [16]: The outstanding Treasury bonds include approximately
            US$79 billion (SEK 654 billion) worth of benchmark
            bonds, approximately US$2.8 billion (SEK 23 billion)
            worth of non-benchmark bonds, and approximately US$11
            billion (SEK 94 billion) worth of inflation linked
            bonds.
       [17]: Other types of Swedish currency-denominated debt
            included approximately US$6.8 billion (SEK 56 billion)
            worth of lottery bonds.  A total of approximately
            US$132 billion (SEK 1086 billion) in Swedish government
            debt was denominated in Swedish kronor.
            Foreign currency-denominated debt amounted to
            approximately  US$41 billion (SEK 342 billion).
            Foreign-currency denominated debt includes
            approximately US$32 billion (SEK 266 billion) worth
            of public issues, US$6.7 billion (SEK 56  billion)
            worth of private placements, and US$2.0 billion
            (SEK 16 billion) worth of commercial paper.
       [18]: OM petition, supra note 7.  OM states that the
            statistics about secondary market trading in Swedish
            debt were derived from data specially prepared by the
            Swedish Central Securities Depository.  Id.
            For the historical 1996 to 1998 secondary market
            trading data discussed in this release, U.S. dollar
            equivalents are based on the conversion rate of SEK
            7.8565 for US$1.00 in effect as of September 30,
            1998.  The exchange rate varied  from 6.5340 to
            7.0114 in 1996, from 6.8074 to 8.0780 in  1997, and
            from 7.5763 to 8.3397 in 1998.
       [19]: OM states that secondary market trading for Swedish
            government debt is primarily conducted on a phone-based
            and screen-based over-the-counter market conducted by a
            number of dealers, with transactions in Treasury bonds
            and Treasury bills registered at the PMX Exchange at
            the end of the trading day.  Id.
       [20]: OM states that secondary market trading in lottery
            bonds was equivalent to approximately US$512 million
            (SEK 4.03 billion) in 1996, US$449 million (SEK 3.53
            billion) in 1997, and US$213 million (SEK 1.67 billion)
            in the first half of 1998.  OM has not provided
            secondary market trading data for other Swedish debt
            securities.  According to OM, transaction data for
            Swedish government debt denominated in foreign
            currencies is extremely difficult to obtain.  OM
            further contends that because a number of Swedish
            government debt securities denominated in U.S. dollars
            have been registered under the Securities Act of 1933,
            and therefore are not eligible for exemption under the
            Rule, secondary market data for securities denominated
            in non-kronor currencies is less significant.  See id.
            OM states that it presently does not intend to list any
            futures on inflation-linked bonds, treasury bonds with
            repurchase agreements, lottery bonds or commercial
            papers.     Id.
       [21]: 15 U.S.C. 78w(a)(2).
       [22]: 15 U.S.C. 78c.
       [23]: Pub. L. No. 104-290, 110 Stat. 3416 (1996).
       [24]: 15 U.S.C. 78f(b).
       [25]: 5 U.S.C. 553(d).