CFTC delivers holiday gift to Wall Street -- Delays EBC and Documentation Requirements

December 2012
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CFTC delivers holiday gift to Wall Street -- Delays EBC and Documentation Requirements

At a glance

This FS Regulatory Brief describes the impact of the Interim Final Rule on registering swap dealers as well as the significant deadlines that remain. The Commodity Futures Trading Commission (CFTC) gave swap dealers a reprieve from the year-end deadline to comply with most of the external business conduct and swap documentation duties to counterparties.

The Commodity Futures Trading Commission (CFTC) gave swap dealers a just-in-time reprieve from the year-end deadline to comply with most of the external business conduct and swap documentation duties to counterparties. A new Interim Final Rule released on December 18, 2012 goes beyond the no-action relief offered by the CFTC thus far to provide a formal extension of compliance deadlines from January 1, 2013 to May 1, 2013 for most external business conduct duties, and to July 1, 2013 for portfolio reconciliation and swap documentation rules. The extension is further evidence that the CFTC is listening to legitimate industry concerns.

This FS Regulatory Brief describes the impact of the Interim Final Rule on registering swap dealers as well as the significant deadlines that remain.

To read this FS Regulatory Brief, please click here.