On December 18, 2012, the Commodity Futures Trading Commission
(CFTC) issued a draft release with interim final rules to extend
the compliance dates for the CFTC's business conduct standards
rules and other CFTC rules relating to portfolio
reconciliation and swap trading documentation requirements. As
explained in a prior
Client Alert, in order to facilitate swap dealers'
compliance with the business conduct standards rules by January 1,
2013, their swap counterparties were being urged to adhere to the
ISDA August 2012 Dodd-Frank Protocol in advance of that date.
The compliance date that would have necessitated adherence to the
ISDA August 2012 Dodd-Frank Protocol by January 1, 2013 has been
extended to May 1, 2013. Thus, market participants now have
additional time to review and complete the adherence process. The
portfolio reconciliation and swap trading documentation
requirements are the subject of a separate protocol (the ISDA
November 2012 DF Protocol, currently in draft form) and the
compliance date for those rules has been extended to July 1,
2013.
The CFTC's press release can be found here.
A pre-publication draft of the interim final rule release can be
found here.
For more information about the ISDA August 2012 Dodd-Frank
Protocol, please see our prior
Client Alert.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
