The CFTC’s recent release of several final rules, including rules regarding registration of swap dealers and major swap participants, allows renewed consideration of the speed and sequencing of implementation of Title VII of Dodd Frank. The attached Update attempts to put recent CFTC actions in perspective, set against the CFTC’s own July 2011 “Effective Date for Swap Regulation” final order and the tentative schedule for further rule releases that Chairman Gensler made public at the CFTC’s January 11 open meeting.

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