The final joint swap definition rules and interpretations issued by the CFTC and SEC under the Dodd-Frank Act went into effect on October 12, 2012, triggering a series of requirements related, among other things, to swap dealer registration, determination of who is a major swap participant, swap data reporting and recordkeeping, status of eligible contract participants, and registration as a commodity pool operator, commodity trading advisor, introducing broker, floor broker, or floor trader. In recent weeks, CFTC staff have issued numerous no-action and interpretative letters and FAQs related to the effectiveness and implementation of several of these requirements.
As swaps market participants gear up for compliance, confusion abounds not only as to the “what” and the “how,” but also the “when.” This webcast will provide an overview of the recent CFTC staff pronouncements and the Agency’s current framework for compliance with the new regime. It will also provide a brief summary of what still remains to be done.
Topics of Discussion:
- Overview of compliance dates
- Staff guidance on swap dealer and major swap participant registration and threshold calculations
- Guidance on intermediary registration
- Guidance on eligible contract participants
- Commodity pools, REITs and securitizations
- What remains to be done
WilmerHale Special Counsel Gail Bernstein and Bruce Fekrat are featured speakers at this event.