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ARTICLE · 21 DECEMBER 2012

CFTC To Extend Compliance Date For ISDA August 2012 Dodd-Frank Protocol

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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.

United StatesFinance and Banking
Dino Wu
Dino Wu
Jeanette Boot
Jeanette Boot
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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,

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