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.