Alert November 23, 2010

CFTC Proposes Compliance Rules for Certain Swap Market Participants

The CFTC proposed rules supplementing the Dodd-Frank Act’s requirements relating to the compliance programs of futures commission merchants, swap dealers and major swap participants.  The proposed rules prescribe the qualifications for a chief compliance officer (“CCO”), define the internal reporting structure for a CCO, standardize CCO duties across all the foregoing entities and establish procedures and additional content requirements for annual CCO reports provided to the organization and the SEC.  Comments on the proposed rules are due by January 18, 2011.