On Friday, October 12, 2012, regulation of swaps under the Dodd-Frank Act by the CFTC officially began. As we have previously reported, compliance with the majority of the Dodd-Frank Act Title VII regulations will be triggered when institutions acting as swap dealers officially register as such — which, for the largest dealers, is on or before December 31, 2012.
Some market participants remain confused about the scope and impact of this change. In partial response to the wave of industry requests for more clarity, the CFTC on October 11th and 12th released a flurry of no-action letters, staff interpretive guidance and Frequently Asked Questions covering various Title VII topics of interest to market participants. This FS Regulatory Brief summarizes the CFTC actions and, as important, what is still not addressed.