CFTC Postpones Key Effective Dates, Resulting In Extra Time For Compliance

On the eve of a critical December 31, 2012 deadline for many market participants in the global over-the-counter ("OTC") derivatives market, the US Commodity Futures Trading Commission ("CFTC") approved interim final rules (the "Rules") for the largest participants in the OTC derivatives market, Swap Dealers and Major Swap Participants, thereby affecting others in the international OTC derivatives market so long as they face Swap Dealers, Major Swap Participants and in some cases their affiliates and divisions or other offices or branches of these large firms. The Commission voted 5-0 via seriatim to approve the Rules, which will become effective immediately upon their publication in the Federal Register.