CFTC Extends Compliance Dates, Delaying Need To Adhere To ISDA Dodd-Frank Protocol

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The CFTC has issued an interim final rule regarding certain business conduct and documentation requirements for swap dealers and major swap participants. The compliance date for the business conduct standards and certain documentation requirements has been extended to May 1, 2013. The compliance date for the other documentation requirements has been extended to July 1, 2013. As a result, swap dealers will now have until May 1, 2013 (as opposed to the previously looming December 31, 2012 date) to amend their master agreements and other swap documentation with counterparties, as through the ISDA Dodd-Frank Protocol. Counterparties to swap dealers thus have a few additional months in which to adhere to the Protocol or put other documentation in place to preserve their ability to trade with such dealers.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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