CFTC Swap Data Recordkeeping and Reporting Requirements

The CFTC has published a final rule to further implement the Commodity Exchange Act with respect to
the new statutory framework regarding swap data recordkeeping and reporting established by the Dodd-Frank Act. The Dodd-Frank Act required rules be adopted by the CFTC for the reporting of data relating to swaps entered into before the date of enactment of the Dodd-Frank Act (‘‘pre-enactment swaps’’) and data relating to swaps entered into on or after the date of enactment of the Dodd-Frank
Act (‘‘transition swaps’’). The final rules establish swap data recordkeeping and reporting requirements for pre-enactment swaps and transition swaps.

The final rules will be effective August 13, 2012.

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