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Volume XIII, Number 34

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The Commodity Futures Trading Commission "CFTC" Extends Compliance Dates for Certain Swap Dealer and Major Swap Participant Requirements

 

The Commodity Futures Trading Commission has issued interim final rules extending the effective dates for certain business conduct and documentation requirements for swap dealers (SDs) and major swap participants (MSPs). Specifically, the CFTC deferred the compliance dates for provisions in Part 23 relating to general records and documentation requirements, including user exemption documentation requirements, until May 1, 2013. In addition, the CFTC deferred the compliance dates for Part 23 provisions relating to portfolio reconciliation and swap trading relationship documentation until July 1, 2013.

The CFTC interim final rule is available here.

©2023 Katten Muchin Rosenman LLPNational Law Review, Volume II, Number 361
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About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm
Partner

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.

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312-902-5372
James M. Brady, Katten Muchin Law Firm, Finance Attorney
Associate

James Brady concentrates his practice in financial services matters.

While in law school, James was an editor of the Michigan Journal of International Law. He also served as a judicial intern to the Honorable Stephen J. Markman of the Michigan Supreme Court. http://www.kattenlaw.com/James-Brady

312-902-5362
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