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ARTICLE · 19 DECEMBER 2012

CFTC’s January 1 Business Conduct And Documentation Deadline Eased

Mayer Brown
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The interim final rules respond to requests for rulemaking from the International Swaps and Derivatives Association, Inc.

United StatesFinance and Banking
Joshua Cohn
Joshua Cohn
Curtis Doty
Curtis Doty
Jerome Roche
Jerome Roche
David Sahr
David Sahr
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Chris Arnold
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Keywords: CFTC, Commodity Futures Trading Commission, swap dealers, SDs, major swap participants, MSPs

The Commodity Futures Trading Commission (the "Commission") today adopted interim final rules that defer the dates by which swap dealers ("SDs") and major swap participants ("MSPs") are required to comply with many provisions of the Commission's external business conduct rules and with certain internal business conduct rules that require agreements or the exchange of information with counterparties. 

Specifically, the interim final rules extend until May 1, 2013 the compliance date for Subpart H of Part 23 of Commission regulations (other than regulations 23.410(a) and (b), 23.431(d), 23.433, 23.434(a)(1) and 23.451). The deferred rules include disclosures of material risks, characteristics and incentives, including disclosure of the pre-trade mid-market mark, scenario analysis, clearing disclosures, the requirement to make counterparty suitability determinations

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