In this report for the Working Group of Commercial Energy Firms, a NERA team led by Vice President and Kurt Strunk and former Vice President Dr. Sharon Brown-Hruska analyzes the incremental costs and benefits associated with the US Commodity Futures Trading Commission’s (CFTC) proposed definition of “Swap Dealer” under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The NERA team performed a detailed analysis of the activities that will be required of entities designated as Swap Dealers by the CFTC and developed estimates of the costs for Nonfinancial Energy Companies to comply with the associated proposed CFTC regulations. NERA also analyzed the potential benefits of the CFTC’s proposed regulation of Nonfinancial Energy Companies falling under the definition of “Swap Dealer.” The report’s cost-benefit analysis demonstrates that the proposed expansive definition of “Swap Dealer” is contrary to the public interest. Under the proposed rulemakings, Nonfinancial Energy Companies that fall within the definition of “Swap Dealer” will face significant increases in incremental costs, while little or no incremental benefit will accrue to over-the-counter (OTC) energy swaps markets and users of OTC energy swaps.