The CFTC Issues Interim Final Rules Extending the Time for Compliance with Certain Business Conduct and Documentation Requirements for Swap Dealers and Major Swap Participants

On December 18, 2012, the US Commodity Futures Trading Commission’s (the “Commission”) approved interim final rules (the “Interim Final Rules”) for swap dealers (“SDs”) and major swap participants (“MSPs”) that delay compliance with certain business conduct and documentation requirements under Part 23 of the Commission’s Regulations until May 1, 2013 and July 1, 2013 (as discussed below).

SDs and MSPs have not only received some relief in the meantime from such requirements, but this also likely gives market participants a little more time to adhere to the ISDA August 2012 Dodd-Frank Protocol (the “Protocol”), as SDs and MSPs will likely not stop trading with a counterparty for failure to adhere to the Protocol by December 31, 2012 since most requirements addressed in the Protocol were extended until July 1, 2013.

The Commission requests comments (to be received no later than 30 days after the date of publication of the Interim Final Rules in the Federal Register) and notes that it will revise the Interim Final Rules, if warranted.

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