Publication of “Swap” Definition Finalizes Compliance Dates

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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.

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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