It has been three years since the first wave of registrants applied to be swap dealers with the Commodity Futures Trading Commission (CFTC). Since then, dealers’ compliance efforts have been challenged by lack of clarity in the rules and a multitude of CFTC no-action letters.
Furthermore, the industry may face even more difficulty if the SEC’s upcoming swap rules end up out-of-sync with the CFTC’s. In short, for swap dealers, it’s hardly “mission accomplished.”
This Regulatory brief provides our view of (a) the key issues that will impact the industry over the next year, and (b) the effect of the SEC’s upcoming rulemakings.