Update on CFTC Dodd-Frank Rulemaking: CFTC Outlines Rulemaking and Implementation Timelines and Announces Delays in Large Trader Reporting Requirements 

October, 2011 - Brian Y. Sung

At its open meeting on September 8, 2011, the Commodity Futures Trading Commission (the “CFTC”):

  • announced that it would not complete its rulemaking process for rules necessary to implement the Title VII swaps-related provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) until 2012; and
  • outlined a proposed sequence of rules to be considered during the remainder of 2011 and the first quarter of 2012.

In addition, the CFTC also:

  • proposed timelines for implementation of proposed clearing, trade execution, trading documentation, and margining requirements (once finalized) (September 8, 2011 meeting); and
  • issued a letter providing temporary relief from its rules regarding large trader reporting of physical commodity swaps activity through November 21, 2011 (for cleared swaps) or January 20, 2012 (for uncleared swaps) (dated September 16, 2011).

Meanwhile, as the rulemaking process continues, the CFTC and the Securities and Exchange Commission (“SEC”) have also drawn increased attention from the House and the Senate, including three recent bills and a formal letter expressing concerns regarding the rulemaking.

For more information, please contact:
Brian Y. Sung
[email protected]



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