The CFTC’s and SEC’s joint final rule defining the term “swap” was published in the Federal Register today, establishing compliance dates for numerous swap-trading regulations, including the following:
October 12, 2012
– Swap Dealers (SDs) and Major Swap Participant (MSPs): Registration, Internal Business Conduct Standards, Reporting and Recordkeeping Requirements for Interest Rate and Credit Swaps
– Position Limits (Spot Month)
– Large Trader Reporting
January 10, 2013
– SDs and MSPs: Reporting and Recordkeeping Requirements for All Swaps
April 10, 2013
– End Users: Reporting and Recordkeeping Requirements for All Swaps
A recap of important definitional concepts and compliance obligations related to the term “swap,” particularly as concerns energy companies, is available here.
[…] Law firm Leonard Street and Deinard published a simple update on the DFA compliance dates here: https://dodd-frank.com/publication-of-swap-definition-finalizes-compliance-dates […]