Client Alert
| October 4, 2010
CFTC Begins Dodd-Frank Rulemaking
On October 1st, the Commodities Futures Trading Commission (the "CFTC") issued the first of many rulemakings pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act") by enacting an interim final rule regarding reporting of swaps executed prior to the enactment of the Dodd-Frank Act. The Dodd-Frank Act mandated that within 90 days of its enactment, on July 21, 2010, the CFTC was required to tell swap participants where and how to report their pre-enactment swaps. Since the CFTC has yet to issue its rules regarding swap data repositories ("SDRs"), the interim rule does not require immediate reporting, but requests swap participants to save their data so that they can report it in the future, after the CFTC has issued reporting requirements and after SDRs are registered.
This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent.
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