Final rules require tape recording by futures commission
merchants, introducing brokers, retail foreign exchange dealers,
and commodity trading advisors; affected CFTC registrants must
implement systems to comply by December 21, 2013.
On December 21, 2012, the Commodity Futures Trading Commission
(CFTC) published in the Federal Register final rules
(Final Rules) for futures commission merchants (FCMs), larger
introducing brokers (IBs), retail foreign exchange dealers (RFEDs),
and commodity trading advisors (CTAs) that are members of a
designated contract market (DCM) or swap execution facility (SEF).
The Final Rules require the recording of oral communications that
lead to the execution of a commodity interest
transaction.1 The Final Rules also conform the
recordkeeping rules for FCMs, IBs, and RFEDs related to futures and
other commodity interests under CFTC Rule 1.35 to those applicable
to swap dealers (SDs) and major swap participants (MSPs) related to
swaps