On January 11, the Commodity Futures Trading Commission (CFTC) adopted three final rules to implement certain requirements contained in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act), including (1) the protection of cleared swaps customer collateral, (2) external business conduct standards for swap dealers and major swap participants, and (3) the registration of swap dealers and major swap participants. The CFTC also adopted proposed rules to implement the Volcker Rule.

It is expected that all of the above items will be published in the Federal Register in the coming weeks. The discussion below is based on the fact sheets on the CFTC’s website and remarks made by CFTC Commissioners and staff at the open meeting.

The next CFTC open meeting is tentatively scheduled for January 25, 2012, at which the CFTC expects to consider final rules pertaining to the further definitions of swap dealer and major swap participant, among other topics. Also, the CFTC has issued a tentative timeline for its issuance of additional final rules and interpretive orders to implement Title VII of the Dodd-Frank Act.

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