Derivatives market participants are one step closer to being able to definitively decide whether they need to register as swap dealers or major swap participants. On April 18, 2012, the CFTC and SEC approved a final rule that defines the terms "swap dealer," "major swap participant" and "eligible contract participant" under the Dodd-Frank Act. The CFTC has laid out a series of fast-approaching compliance deadlines for swap dealer/MSP registrants in October that will hold firm absent significant regulatory delay.
As in other Dodd-Frank regulatory areas, whether you are swept into or remain out of the swap dealer/MSP definitions, you need a strategy to navigate through Title VII. This FS Regulatory Brief offers guidance and answers key questions on what to do next for sell- and buy- side derivatives players alike.